Indiana FSSA Medicaid · October 24, 2026 · Primary source
BT202543: IHCP clarifies billing requirements for ABA claims with primary payer
Summary
The Indiana Health Coverage Programs (IHCP) issued a clarifying FAQ bulletin (BT202543, March 27, 2025) addressing how ABA therapy providers must handle claims when the member's primary payer does not recognize a Registered Behavior Technician (RBT) or Board Certified Assistant Behavior Analyst (BCaBA) as a rendering provider. When the primary carrier does not recognize those credential types, providers must submit the primary claim with a supervising practitioner (BCBA or HSPP) as the rendering provider. The secondary Medicaid claim must then list the RBT or BCaBA as rendering provider and include third-party liability information from the primary payer.
What this may mean
Indiana Medicaid ABA providers billing in a coordination-of-benefits context face a specific two-claim sequencing rule: the primary claim must use a BCBA or HSPP as rendering provider, and the secondary IHCP claim must use the RBT or BCaBA with TPL data. Failure to follow this sequencing creates a billing compliance exposure under IHCP rules. The bulletin is effective immediately and supplements prior guidance in BT202519.
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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