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Indiana FSSA Medicaid · October 24, 2026 · Primary source

BT2024194: IHCP clarifies ABA documentation requirements and updates provider enrollment requirements

Score 58PRIMARYregulatoryState MedicaidIN

Summary

Indiana IHCP Bulletin BT2024194, issued November 29, 2024, establishes revised documentation requirements and new provider enrollment rules for applied behavior analysis (ABA) therapy under Indiana Medicaid, applicable to all IHCP programs. Effective December 18, 2024, existing ABA Therapist enrollees under provider type 11, specialty 615 are reclassified as high risk and subject to fingerprint background checks and site visits, and two new specialties are created for bachelor's-level and Registered Behavior Technician providers. Beginning April 1, 2025, the rendering provider NPI on ABA claims must match the procedure code modifier indicating the provider's level, with school corporations exempt.

What this may mean

Existing ABA therapy providers enrolled under specialty 615 face mandatory reclassification to high-risk status with associated fingerprint and site-visit screening requirements triggered by letters from Gainwell Technologies. New bachelor's-level (specialty 624) and RBT (specialty 625) providers may enroll starting December 18, 2024, but only as rendering providers classified at high risk with fingerprint background check requirements. Claims for ABA therapy services submitted after April 1, 2025 with a rendering provider NPI that does not match the procedure code modifier are subject to denial.

Informational only. Not legal, medical, financial, or other professional advice. Always consult a qualified professional familiar with your specific facts before relying on any item.

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