Regulatory Analysis · Indiana Medicaid · Effective April 1, 2026

Effective April 1, 2026, Indiana's Family and Social Services Administration cut individual ABA reimbursement rates by 6 percent under Office of Medicaid Policy and Planning bulletin BT202627, with a further 4 percent reduction scheduled for April 1, 2027. The same overhaul restricts ABA coverage to EPSDT members under age 21 (members 21 and older lose coverage for dates of service from October 1, 2026), caps targeted ABA at 15 hours a week, and sets a 4,000-hour lifetime limit on comprehensive ABA. A separate bulletin, BT202646, makes ACQ or BHCOE accreditation a condition of IHCP enrollment from October 1, 2027. For BCBAs, RBTs, and the billing teams behind them, the operational shift is bigger than the rate cut: authorization tracking must be rebuilt around hour-bank depletion, not authorization expiry.

-6%

Individual ABA Rates

Effective April 1, 2026 under FSSA/OMPP bulletin BT202627.

-4%

Second Cut Scheduled

Takes effect April 1, 2027. Model both steps in every forecast now.

<21

EPSDT Members Only

ABA coverage restricted to EPSDT-eligible members under age 21; members 21 and older covered only through September 30, 2026.

15hrs/wk

Targeted ABA Cap

Targeted ABA up to 15 hours a week; comprehensive ABA (16 or more hours) draws on the lifetime bank.

4,000

Lifetime Hour Limit

A fixed lifetime bank of ABA hours per member. Every billed hour draws it down.

≈2.6yrs

What The Bank Buys

4,000 hours equals roughly 2.6 years of 30-hour weeks.

The number that matters: 4,000 hours

Before April 2026, an Indiana ABA authorization ended on a date. Your practice management system could see that date, alert on it, and queue the reauthorization. Under BT202627, every billed hour also permanently draws down a finite lifetime bank. A member authorized at 30 hours per week exhausts the entire benefit in roughly 2.6 years. Denial risk no longer arrives only on a calendar date you can see; it arrives on a cumulative threshold you have to compute across the member's full claims history. If your system cannot answer "how many lifetime ABA hours has this member consumed to date," you cannot see the cliff until you are billing off the edge of it.

Lifetime hour bank · one member · full-intensity treatment

01,0002,0003,0004,000 hrs

4,000 lifetime hours ÷ 30 hrs / week = ≈133 weeks ≈ roughly 2.6 years

How Indiana got here

Nov 12, 2025
The FSSA ABA Work Group issues its recommendations, the policy blueprint for the overhaul.
Rulemaking
FSSA moves the policy toward administrative code via 405 IAC rulemaking notice 20260225-IR-405260061ONA in the Indiana Register.
Apr 1, 2026
Bulletin BT202627 takes effect: 6% rate cut, EPSDT-only coverage, a 15-hour weekly cap on targeted ABA and a 4,000-hour lifetime cap on comprehensive ABA. Bulletin BT202646 (March 26, 2026) separately sets an accreditation mandate for October 1, 2027.
Apr 1, 2027
The scheduled second reduction lands: another 4% off individual ABA rates.

The five changes, itemized

1. Rates step down twice

Individual ABA rates fell 6% on April 1, 2026, and a scheduled additional 4% reduction follows on April 1, 2027. Any budget, staffing plan, or payer-mix model built on the pre-April fee schedule is already stale, and the 2027 step should be in every forecast today, not next spring.

2. Coverage narrows to EPSDT under 21

ABA is now an EPSDT benefit for members under age 21; members 21 and older could continue only through September 30, 2026. Members approaching their 21st birthday are approaching a coverage boundary, so census review and transition planning become recurring operational tasks, not one-time cleanups.

3. Targeted ABA is capped at 15 hours a week

BT202627 sets no diagnosis-based weekly cap. It defines comprehensive ABA as 16 or more hours a week, billed with modifier UA against the lifetime bank, and caps targeted ABA at 15 hours a week. Treatment plans filed in the wrong tier create denial exposure at submission, so BCBAs writing plans and the authorization team validating them need the tier rules in the same workflow.

4. A 4,000-hour lifetime limit

Every authorization is now a draw against a finite bank. Cumulative lifetime utilization becomes a first-class billing data point, and depletion forecasting, not just expiration alerting, becomes the core of authorization management.

5. Accreditation gates enrollment

Under bulletin BT202646, ACQ or BHCOE accreditation becomes a condition of IHCP enrollment on October 1, 2027, and enrolled groups had to show by August 1, 2026 that they had started. For unaccredited organizations this is an enrollment problem, not a quality initiative, and accreditation timelines run in months, not weeks.

The federal tension worth naming: EPSDT carries a federal medical-necessity guarantee for members under 21, so hard caps inside an EPSDT benefit tend to operate in practice as review thresholds rather than absolute walls. Providers who build the medical-necessity file rigorously before a member's bank runs low will be positioned for exception review. Providers who first discover the cap on a denial will not.

The operator checklist

Build the lifetime hour ledger. Reconstruct cumulative ABA hours per member from claims history, then keep the ledger current with every remit. This is the single data asset the whole overhaul turns on.
Rebuild authorization alerts around depletion. Add projected bank-exhaustion dates, computed from authorized weekly intensity, alongside auth end-dates. Escalate when the projected depletion date lands inside the current treatment plan.
Reforecast revenue at the new fee schedule. Apply the 6% cut to the current book and model the additional 4% for April 1, 2027 now, so staffing and payer-mix decisions are made against the real numbers.
Audit the census for age-out risk. Flag every member approaching age 21, and put transition planning on a calendar instead of waiting for eligibility denials to announce the boundary.
Reconcile treatment plans against the comprehensive and targeted tiers. Check requested intensity against the 15-hour targeted cap and the lifetime bank before submission, and route over-cap requests through documented medical-necessity review.
Start ACQ or BHCOE accreditation immediately if unaccredited. Enrollment depends on it from October 1, 2027, and the runway is measured in months.
Front-load EPSDT medical-necessity documentation. Build the exception file while the bank is healthy, so the record exists before any cap threshold is reached.

Sources

Indiana FSSA / Office of Medicaid Policy and Planning, bulletin BT202627, effective April 1, 2026.
Indiana Health Coverage Programs bulletin BT202646, ABA agency accreditation, March 26, 2026.
Indiana Register, 405 IAC rulemaking notice 20260225-IR-405260061ONA.
Indiana FSSA ABA Work Group recommendations, November 12, 2025.

Hour-bank tracking is now a billing discipline. We build it.

ASP-RCM Solutions runs revenue cycle operations for ABA organizations, with BCBAs' and RBTs' workflows, not generic medical billing, at the center. For Indiana providers that means lifetime hour ledgers rebuilt from claims history, authorization management keyed to depletion dates, treatment-plan intensity checks against the comprehensive and targeted tiers, and EPSDT documentation assembled before it is needed. Our ABA payer policy matrix spans 52 jurisdictions, so when a state rewrites its benefit the way Indiana just did, the playbook is already on the shelf.

Talk to the ABA billing team

The number that matters: 4,000 hours

How Indiana got here

The five changes, itemized

1. Rates step down twice

2. Coverage narrows to EPSDT under 21

3. Targeted ABA is capped at 15 hours a week

4. A 4,000-hour lifetime limit

5. Accreditation gates enrollment

The operator checklist

Sources

Hour-bank tracking is now a billing discipline. We build it.

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