Practice requirements for ABA providers in Indiana

No IDOH health-facility license applies to a typical outpatient ABA clinic. IC 16-18-2-167 (2026 Code) defines a health facility as a place providing reception, accommodation, board, care, or treatment beyond a continuous 24-hour period in a week to more than four individuals because of illness, infirmity, or impairment, and it excludes offices of practitioners of the healing arts. There is no Professional Licensing Agency facility or agency license for an ABA clinic. Practicing applied behavior analysis, or using LBA, LABA, or similar titles, requires an individual license under IC 25-8.5 (HEA 1516 / P.L.212-2021, effective July 1, 2021; the section is still listed in the 2026 Code). A violation is a Class A misdemeanor (IC 25-8.5-3-7). IC 25-8.5-3-6(b)(D) excepts an applied behavior analysis direct contact technician, and a family member implementing a plan in the family home, who does not use a protected title and acts under the extended authority and direction of a behavior analyst or assistant behavior analyst licensed under that chapter. PLA does not license RBTs. For Medicaid, the agency must be an IHCP group enrollment. Any new group must enroll as provider type 11, specialty 615 – ABA Therapist (Masters/Doctoral or HSPP); existing groups may keep their current enrollment (BT202519, Feb. 6, 2025). Group and billing specialty 615 enrollments are high risk at initial enrollment and require a fingerprint background check and a site visit (BT2024194; effective Dec. 18, 2024). A CMS-approved moratorium effective June 6, 2026, for an initial six months and extendable in six-month increments, blocks brand-new ABA group enrollments and changes of ownership of existing ABA agencies. It does not block individual rendering enrollments. Limited access exceptions require accreditation as described in BT202646 and an email request to OMPPProviderRelations@fssa.in.gov (BT202692, June 4, 2026). Beginning Oct. 1, 2027, every new and existing ABA group enrollment must be accredited by the Autism Commission on Quality (ACQ) or the Behavioral Health Center of Excellence (BHCOE) and remain accredited. Groups already enrolled had to submit proof that accreditation was started, or upload an existing accreditation, by Aug. 1, 2026 (to INXIXabaenrollments@gainwelltechnologies.com or via the IHCP Portal), or the enrollment is deactivated (BT202646, Mar. 26, 2026; BT2026118, July 14, 2026). A prior BHCOE accreditation is accepted until the agency reaccredits with ACQ. ACQ accredits the ABA service line at the state level rather than each site, but every Indiana location offering that line must be reported to ACQ, and a provider with IHCP service locations in more than one state must accredit the ABA line in each of those states (BT202660, Apr. 28, 2026).

Licensure and Medicaid use different checks. An initial licensed behavior analyst or licensed assistant behavior analyst must submit to a national criminal history background check under IC 25-1-1.1-4 (IC 25-8.5-3-1(2), IC 25-8.5-3-2, and IC 25-0.5-1-2.7). That check is the FBI criminal-history record system based on fingerprint identification or another method of positive identification (IC 25-1-1.1-4(b)), at the applicant's cost. PLA requires IdentoGO fingerprints only after the agency emails that the application was received; prints taken earlier are invalid and must be repeated. IDEMIA service codes are 24YTSG for Licensed Behavior Analyst and 24YTTY for Licensed Assistant Behavior Analyst. Results are sent to PLA. PLA states a check is not required for renewal or reinstatement, but IC 25-1-1.1-4(e) allows a random audit requiring a new national check at renewal, at the individual's cost. The applicant must show no conviction of a crime that has a direct bearing on the ability to practice competently, and no out-of-state licensure or certification discipline for inability to practice without endangering the public. PLA reviews criminal history case by case. For IHCP, provider type 11 specialties 615 (ABA Therapist, Masters/Doctoral or HSPP), 624 (BCaBA), and 625 (RBT) are high risk at initial enrollment. Each rendering individual, and for an organization every person with at least 5% direct or indirect ownership or control (including the board of a nonprofit), must complete an Indiana State Police fingerprint-based state and federal background check before the enrollment application is submitted. Another state's results cannot be substituted. A confirmation number from an IHCP fingerprint check within the prior six months may be reused. The individual pays the fingerprint fee. Results go to FSSA, not the agency. Existing rendering providers were to complete fingerprints by July 1, 2025. An already enrolled rendering provider who is later linked to another group does not need a new check (BT2024194, Nov. 29, 2024; BT202519, Feb. 6, 2025; IHCP Provider Enrollment Risk Levels and Screening page). Enrolled school corporations are not subject to the fingerprint requirement; enrolled group providers that render ABA in schools are. FSSA/OMPP may deny or terminate participation if the provider or a person owning at least 5% has been convicted, pleaded guilty, or received an adjudicated pretrial diversion for an offense inconsistent with the best interest of members or the program. The published examples, which are not exhaustive, are felony crimes against persons (including murder, rape, and assault); financial crimes (including extortion, embezzlement, income-tax evasion, and insurance fraud); an offense that may subject members to an undue risk of harm; sexual misconduct that may subject members to an undue risk of harm; a controlled-substance crime; abuse or neglect of a child or adult; a crime involving a firearm or other deadly weapon; and crimes directly related to the ability to provide Medicaid services. The point-scoring sheets linked on that page are labeled for home health, DME, and waiver services, and for transportation. No Indiana statute was found that requires a background check for a direct-contact technician who is not applying for an LBA or LABA license and is not enrolling in IHCP.

Indiana does not set an RBT training-hour or examination rule and does not license RBTs; PLA directs RBT applicants to the BACB. To enroll and bill IHCP, the person must hold the credential for the specialty: a credentialed RBT for type 11 specialty 625, a BCaBA for specialty 624, and an HSPP license, BCBA, or BCBA-D for specialty 615, plus a Type 1 NPI. RBTs and BCaBAs had to be enrolled by April 1, 2025 (BT2024194; BT202519). 405 IAC 5-22-12(c)–(d), readopted May 30, 2023, allows ABA to be provided by an HSPP, a licensed or board-certified behavior analyst, or a credentialed RBT, and requires that services by a bachelor-level BCaBA or a credentialed RBT be supervised by a master's-level BCBA, a BCBA-D, or an HSPP. 844 IAC 21-4-6 (filed Mar. 11, 2025; 20250409-IR-844240437FRA) makes the behavior analyst responsible for appropriate supervision of staff, paraprofessionals, BCaBAs, and individuals training to be behavior analysts who assist with or carry out treatment. Supervision includes direct observation of the supervisee delivering services, in person and by visual electronic means. The rule states no hour ratio. An LABA must work under an LBA or a licensed psychologist approved by the BACB, under a signed supervision contract (844 IAC 21-4-6(b)–(c)). IC 25-8.5-3-2(b) requires the LABA to be directly supervised by a licensed behavior analyst and to submit a written record of that supervision to the committee. LBA and LABA licenses expire Dec. 31 of odd-numbered years and, once renewed, are valid for two years. The licensee must attest to current BACB certification. Renewal CE under 844 IAC 21-3-1 is one unit in trauma-informed care and one unit in either abuse and neglect or mandatory reporting. Those units may also be used for BACB certification. PLA requires the CE to fall in the licensure cycle and to come from an approved sponsor. At renewal, an LABA must have a current supervising LBA and must submit the written supervision record for the preceding renewal period. Medicaid ratio, effective April 1, 2026: at least one hour of supervision by a BCBA or another IHCP-approved qualifying supervising clinician for every eight hours of technician-delivered services under CPT 97153 and 97154, measured each calendar month and for each member, not aggregated across technicians or members (BT202627, Feb. 26, 2026; BT202662, Apr. 28, 2026). If the member receives fewer than eight hours that month, supervision must still be medically appropriate and proportional. Documented billable and nonbillable member-specific clinical supervision counts; scheduling, performance reviews, and staff meetings not tied to that member do not. CPT 97155 counts toward the 1:8 ratio only when the BCBA, BCBA-D, or other qualifying supervisor is actively directing a technician who is implementing a modified protocol, and 97155 may be billed concurrently only with 97153 and 97154. Synchronous telehealth supervision may use modifier 95 but is intended to supplement, not replace, the majority of in-person services. Missing the ratio can result in claim adjustment, recoupment, or other administrative action. For dates of service on or after April 1, 2026, 97153 may be rendered by an RBT (U1; specialty 625), a BCaBA (U2; specialty 624), or a BCBA-D, BCBA, or HSPP (U3; specialty 615). Before that date, 97153 was reimbursable only when rendered by an RBT. School corporations are exempt from listing an enrolled rendering specialty, but the person who renders the service must still meet the qualifications for that service.

IHCP covers ABA through EPSDT. 405 IAC 5-22-12(b) makes services available from the initial diagnosis through 20 years of age. Effective April 1, 2026, coverage is only through EPSDT (42 CFR 441.50, individuals under 21). Members age 21 or older who were already receiving ABA could continue, when medically necessary, during a transition from April 1, 2026, through Sept. 30, 2026. For dates of service on or after Oct. 1, 2026, IHCP will not authorize or reimburse ABA for members 21 or older (BT202627). All covered ABA requires prior authorization. The code allows an initial course of up to six months and says the office shall not approve a request covering more than six months at one time; continuation requires a new request with an updated treatment plan (405 IAC 5-22-12(f)–(g)). The same rule caps direct ABA at 40 hours per week unless additional prior authorization finds more hours medically necessary (405 IAC 5-22-12(h)). Separately, for dates of service on or after April 1, 2026, BT202627 defines comprehensive ABA as an intensive model of 16 or more hours per week and limits it to 4,000 hours (16,000 units) over a lifetime, after which targeted ABA is limited to 15 hours per week. Further comprehensive hours require a later medical-necessity finding by FSSA, the member's managed-care entity, or a delegated entity, under EPSDT. The lifetime allocation does not apply to ABA furnished by a school corporation. CPT 97155 and 97156 are outside the 4,000-hour bank. Comprehensive services use modifier UA on the prior-authorization request and the claim when the request is submitted on or after April 1, 2026. Caregiver coaching must be included in every ABA prior authorization. Up to 18 hours of caregiver coaching and training are allowed in a standard six-month authorization, using 97156 and 97157. For comprehensive ABA, for dates of service on or after June 1, 2026, the floor is two hours per month or 12 hours per standard six-month period, still within the 18-hour maximum unless more is medically necessary. Targeted ABA has no fixed monthly or six-month floor (BT202662). A statement of need and a referral are the same document (BT2026160, Sept. 29, 2026). It must be from a doctoral-level licensed clinical psychologist endorsed as an HSPP, a licensed physician, a licensed APRN, or a licensed physician assistant, each with specialized training in the current DSM autism criteria. It cannot be completed by a BCaBA, a master's-level BCBA, a physical therapist, a speech-language pathologist, or an occupational therapist. It is required at onset if the comprehensive diagnostic evaluation is more than one year old, at reauthorization when that evaluation becomes more than one year old, and with a new prior authorization after a six-month gap in ABA (and with each new prior authorization if six-month gaps continue). It is not required with every reauthorization or every six months. Reassessment and an updated treatment plan must be completed at least every six months. Effective April 1, 2026, CPT 97151, 97152, 97153, 97154, and 0373T cannot be billed with modifier 95; those services must be delivered in person (BT202627). 405 IAC 5-22-12(d)(2) still says services by a credentialed RBT are reimbursed at 75% of the rate on file, while BT202627 Table 1 sets the same April 1, 2026 maximum of $16.04 per 15 minutes for 97153 billed U1, U2, or U3 ($15.39 on or after April 1, 2027). No rule amendment repealing the 75% clause was found. As of Oct. 21, 2026, no bulletin was found extending the June 6, 2026 group moratorium past its initial six months (about Dec. 6, 2026). 460 IAC 6-5-32, a DDRS rule readopted Nov. 9, 2020, still sets separate qualifications for an entity approved to provide ABA under the DDRS supported-living rules: a lead therapist must be a licensed psychiatrist or an HSPP psychologist and have 1,500 hours of ABA or equivalent training or supervised experience with children with a pervasive developmental disorder plus two years as an independent practitioner and supervisor; a senior therapist must be a psychotherapist or have 3,000 hours, including at least 400 hours with autistic disorder, Asperger's disorder, or a pervasive developmental disorder, and 10 related CE hours a year; line staff must be at least in the second year of college with 30 hours of intensive behavioral treatment or 160 hours working with children with autism, or be at least 18, a high-school graduate, and have 2,000 hours of training or supervised experience. Whether BDDS still approves marketplace ABA providers under that section in 2026 was not confirmed. IHCP state-plan enrollment uses the specialty and credential rules above.

Per BT202662, effective April 1, 2026, the supervision ratio is 1:8 for RBT-delivered 97153/97154, measured monthly per member; qualifying documented nonbillable clinical supervision also counts. The 2024 ABA fee schedule separately describes technician services as administered 'under the direction of a physician or other qualified health care professional'.