Indiana Family and Social Services Administration (FSSA) Secretary Mitch Roob has announced the recommendations of the Applied Behavior Analysis (ABA) Working Group, convened earlier this year to address the rapid growth and sustainability challenges of Medicaid-funded ABA therapy.
The Working Group’s Process
The ABA Working Group was led by FSSA Deputy Secretary Eric Miller and Indiana 211 Director Tara Morse. The group included Representative Robb Greene and other state leaders, clinicians, educators, parents, providers, and advocacy organizations, including The Arc of Indiana CEO Kim Dodson.
Key Findings
- Unsustainable growth: Without reform, Medicaid spending on ABA therapy was projected to reach $825 million by 2029.
- Quality concerns: A federal audit found $56.5 million in improper payments and systemic documentation failures
- Provider distribution: Services are concentrated in urban areas, leaving rural counties underserved.
- Lack of oversight: No dedicated program office, weak supervision standards, and no accreditation requirements.
Recommendations
- A lifetime guidance of up to 4,000 hours of comprehensive ABA (with eligibility for continued targeted ABA afterward), tracked through an updated prior authorization process.
- Requiring 12–18 hours of caregiver coaching per authorization period.
- Establishing guidance for appropriate use of group therapy hours.
- Setting standardized BCBA (Board Certified Behavior Analyst)-to-RBT (Registered Behavior Technician) supervision ratios.
- Requiring state-determined accreditation for provider agencies.
- Implementing a temporary moratorium on new ABA clinic sites.
- Minimizing additional barriers for RBTs to participate in Medicaid networks.
- Establishing fair and predictable reimbursement rates, including potential quality incentives.
- Creating an ABA Program Office within FSSA to oversee quality and utilization management.
Next Steps
The recommendations will move into the implementation phase. Decisions on rates are expected closer to FSSA’s presentation before the State Budget Committee next month.
The Arc of Indiana’s Response
The following is The Arc’s response to the recommendations.
The Working Group included a broad group of stakeholders who were provided with comprehensive information and the time and space to express concerns and ask questions.
The recommendations provide a balanced approach by calling on providers to be part of the solution to the growing cost of ABA, rather than just putting the burden on families
The Arc is pleased that the recommendations do not include the previous administration’s directive to place a three-year, lifetime, retroactive cap on ABA therapy. The recommended lifetime cap of 4,000 hours for group therapy and allowance for targeted or individual ABA, with a documented need, offers a far better approach. To clarify, targeted or individual ABA would not be counted toward the 4,000 hours.
It is also positive that the recommendations include allowing ABA to be available to people who do not have an autism diagnosis if proven medically necessary.
It is important that the recommendations include requiring ABA providers to be certified and that a conversation about value-based incentives will continue to ensure quality services are provided.
The Arc will continue to closely monitor this issue and the rollout of the recommendations.