Families of children with autism in Indiana are confronting alarming challenges following the announcement of major changes to Medicaid coverage for Applied Behavior Analysis (ABA) therapy. These changes—introduced without input from families, clinicians, or providers—signal a troubling shift in how the state plans to support children on the autism spectrum. The modifications include:
- A 30-hour weekly limit on ABA therapy per child.
- A three-year lifetime cap on ABA services per child.
- Mandatory credentialing for all Registered Behavior Technicians (RBTs).
“These policies would create significant barriers for children with autism to access the most basic, evidence-based treatment for their diagnosis,” said Emily Roche, VP of Payer Contracting at Bierman Autism Centers. “Medicaid’s proposed effective date of April 1, 2025, is clearly rushed. We believe they are pushing this timeline because these ambiguous policies won’t hold up under adequate review.”
These abrupt policy changes have sparked concern not just among healthcare providers, but also among families and legal advocates. The cuts reflect what many believe is a broader trend of proposed Medicaid cuts aimed at reducing expenditures—at the expense of Indiana’s most vulnerable children.
Children with autism require individualized care, often with high treatment intensity, particularly during early developmental windows. Clinical research consistently supports the need for 30 or more hours of therapy per week over multiple years to achieve meaningful outcomes. By imposing these new limits, Indiana Medicaid is stripping away the very foundation of care for those with the most complex needs.
“These caps will harm the children who need care the most,” Roche emphasized. This concern is amplified by the fact that Medicaid’s role is to serve populations that cannot otherwise afford healthcare. Cutting essential therapy access under the guise of administrative reform undermines that mission entirely.
Federal Mental Health Parity laws explicitly prohibit insurers, including Medicaid, from placing arbitrary limitations on mental health services that aren’t equally applied to medical benefits. These new caps may place Indiana Medicaid in direct violation of those laws.
“Medicaid is required, per their own regulations, to provide medically necessary treatment, including the necessary dosage, and should not be allowed to implement these caps,” Roche added.
Before the policy changes have even gone into effect, providers are already reporting new authorization hurdles and service denials that contradict established clinical practice. These barriers include added paperwork and required assessments that are neither practical nor developmentally appropriate.
A prime example is the mandated use of the Behavior Assessment System for Children, Parenting Relationship Questionnaire (BASC-PRQ)—an evaluation tool that cannot be used on children under 2 years old. Despite this limitation, Medicaid has begun denying treatment requests when this assessment is not included for toddlers, leading to families being unjustly cut off from care.
Bierman Autism Centers is currently assisting a family whose child was fully denied services solely because the BASC-PRQ was not administered—despite the child being under the age threshold for which it is valid. These cases point to a flawed implementation process that lacks clinical oversight and is already harming children before the official launch date.
While Indiana’s Medicaid Director, Cora Steinmetz, claims the policy aligns with MCG Medicaid Necessity Criteria, key stakeholders from the autism services field are pushing back. One such leader is Mariel Fernandez, VP of Government Affairs at the Council of Autism Service Providers (CASP), who expressed deep concerns regarding both the content and intent behind the policy.
“One critical consideration is the role of the recent Office of the Inspector General (OIG) report in the decisions made by Indiana Medicaid,” Fernandez explained. “The OIG report was unfavorable and did not paint ABA providers in a positive light, citing serious implications related to potential fraud, waste, and abuse. However, the report also fairly acknowledged that Indiana Medicaid failed to provide adequate policy requirements, training, or oversight for the ABA benefit.”
Fernandez continued, “CASP has serious concerns with the proposed hard caps, which limit care to 30 hours per week for up to three years. These caps disregard the evidence-based needs of children and the best practices for ABA therapy. We also understand that the new Registered Behavior Technician (RBT) enrollment requirements create additional administrative burdens for providers, which will further hinder access to care.”
The bigger issue, Fernandez added, lies in Medicaid’s failure to focus on long-term, systemic improvements. Short-term limitations and reactive policies risk compromising the quality and accessibility of ABA services. “It is essential to acknowledge the context provided by the OIG report and the need for improved oversight and training to ensure Medicaid services meet the needs of children with autism.”
Concerns extend beyond clinical and financial implications. Stakeholders argue that the way these changes were introduced violates both state and federal procedural requirements. No public hearing was held. No formal comment period was offered. And there is no indication that the policy was reviewed by the Indiana Attorney General or the Governor.
Roche added, “Medicaid bypassed the proper rule-making procedures, failing to hold a required public comment period or public hearing. It is also unclear whether these changes were approved by the Attorney General and Governor.” Such disregard for legal process raises red flags for advocates, who insist that any policy affecting vulnerable populations must be subject to rigorous scrutiny.
“Medicaid needs to be held accountable to their obligations—not only to follow federal law and state procedures—but to protect our most vulnerable children,” Roche said. “As a government agency, Medicaid should not be allowed to implement such harmful policies that violate a host of laws and regulations.”
As Indiana prepares to move forward with these sweeping changes, Bierman Autism Centers is calling for a pause on implementation. They urge collaboration with families, clinical professionals, and advocacy groups to ensure that reforms serve the needs of children—not hinder them.
“This is not the time for rushed decisions. It’s time to listen to the people who understand the importance of evidence-based ABA therapy,” Roche concluded.
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