Our Response to the Indiana ABA Workgroup Recommendations
Susan Crowell, Executive Director of My Autism Ally and autism parent, would like to publicly thank Governor Braun with my selection to the Indiana's Applied Behavior Analysis Therapy Work Group. After several meetings from May - September 2025, our group proposed multiple recommendations. These recommendations will cut the state's Medicaid obligation significantly, which was the focus this group was tasked with. There are several areas where I believe we made necessary improvements to maintain high quality ABA Therapy services;
Requiring caregiver involvement to reinforce ABA strategies across daily routines.
Establish BCBA-to-RBT supervision ratios.
Removing virtual oversight of RBT’s.
Ensure commercial insurers reimburse ABA therapy above Medicaid rates.
Strengthen collaboration with schools to support smoother transitions.
Enhance state’s third-party liability (TPL) tracking methods to bill additional costs of ABA therapy to commercial insurers.
However, it is my opinion that the 4,000-hour cap for ABA Therapy ultimately will not address why the Medicaid budget has grown significantly for the state. What needs addressed is the lack of audits and financial oversight by the state of Indiana as it pertains to Medicaid funding. Let's be clear, there are already rules in place and laws on the books. The problem is that the state of Indiana and Indiana Medicaid are not consistently following them. Because of the lack of consistent oversight, autistics, their families and the ethical providers that follow the rules are paying the price. In this release below, we see them admit this problem, however there are no measurable recommendations to fix this issue other than to increase the level of documentation on all providers. This will increase costs for providers yet does not address the central issue. What good is more documentation if the documentation does not address the core problem?
Over and over again this year we have received cuts to disability services. Each time, we are told the cuts to services for clients are a necessary response to the overbilling by unethical providers. While at the same time, dismissing the fact that Medicaid willingly ignored its own rules already in place regarding auditing and billing.
The resulting caps to services to ABA Therapy will be devastating for Hoosier autistics and their families. High quality ABA Therapy providers around the state will be forced to close, hurting families and costing hard working Hoosiers their jobs.
Why will ABA Clinics close?
The state is choosing to cut services while simultaneously cutting reimbursement rates.
New credentialing requirements for RBT’s hurt working families by treating these entry level positions with the same level of documentation requirements as doctors. This is an excellent example of burdensome regulation that increases costs for everyone, including costs to the state for managing all of the excessive paperwork.
As stated in the recommendations, the state will “Adjust reimbursement rates for individual ABA therapy as deemed necessary to stay within the agency’s appropriated budget.”
How are high quality, ethical ABA Therapy clinics supposed to remain in business if the state’s recommendations continually add costs, unnecessary regulation and reinforces a mentality where only the providers that can do it the cheapest can survive? Without changes, these recommendations will reduce the overall effectiveness of ABA Therapy as a treatment to the detriment of the children who need it the most. As outlined, these recommendations do not protect children, preserve access, or improve quality. However, it does incentivize providers to figure out ways to make it cheaper, by delivering a modified version of the service.
As an autism parent I'm frustrated. As a Hoosier taxpayer, I'm outraged. The current leadership apparently isn't interested in going after Medicaid “fraud and abuse” and thinks that the “waste” is the individuals in need of services. Let’s also not forget, the ABA Therapy providers who exploited the loop hole that Indiana Medicaid created when they removed the standardized rates, are better positioned financially to survive these cuts to ABA Therapy than the ethical providers that were unaware of or did not exploit the loop hole. This puts many of our Hoosier owned ABA Therapy providers at a disadvantage.
We can do better for Hoosier autistics and their families. What’s disappointing is that we know how and instead we choose not to.
Always Advocating,
Susan Crowell
Founder and Executive Director
My Autism Ally
scrowell@myautismally.org
Below is the public statement released by FSSA on November 12, 2025. NOTE: This does not include all of the recommendations from the workgroup.
FSSA Announces ABA Working Group Recommendations to Protect Access, Improve Quality, and Ensure Sustainability of Autism Therapy
INDIANAPOLIS – Indiana Family and Social Services Administration (FSSA) Secretary Mitch Roob today 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.
ABA therapy is a widely used, evidence-based treatment for children with autism spectrum disorder (ASD). For many Hoosier families, it has been life-changing—helping children develop essential skills, reduce barriers, and increase independence. But while the therapy’s value is clear, the way Indiana’s Medicaid program has managed it since coverage began in 2015 has created serious challenges.
“When Medicaid coverage for ABA therapy began in Indiana, the program was small and costs were manageable,” said Deputy Secretary Eric Miller. “But with little oversight, spending skyrocketed to unsustainable levels. These recommendations protect access, improve quality, and ensure the program is sustainable for the long term.”
Background: How We Got Here
2015–2017: Indiana began covering ABA therapy under Medicaid. With costs around $17 million annually, the lack of oversight was not seen as urgent. Providers were reimbursed based on a percentage of their reported costs.
2017–2023: As autism diagnoses increased and ABA therapy expanded, costs ballooned to $611 million by 2023—an almost 3,000% increase in six years. Managed Care Entities raised alarms, but the program had already grown to an unmanageable size.
Prior Administration: In response, standardized rates were introduced in January 2024, but costs continued to rise as utilization increased. A State Plan Amendment (SPA) was then proposed to cap ABA therapy at three years, which would have removed half of children from services by April 2025, because the 3-year therapy limitation on services was to be applied retroactively. Schools were expected to absorb these children but had not been consulted and were unprepared.
Governor Braun’s Approach: Upon taking office, Governor Braun rejected this approach, stating Indiana would not retroactively apply ABA therapy limitations to allow for appropriate transitions for children and their families. Instead, through Executive Order, he directed FSSA, in collaboration with the Department of Education, to form the ABA Working Group to evaluate and develop cost containment strategies that minimize the negative impact felt by ABA enrollees and their families.
The Working Group’s Process
The ABA Working Group, led by FSSA Deputy Secretary Eric Miller and Indiana 211 Director Tara Morse. The group included Shelbyville Representative Robb Greene and other state leaders, clinicians, educators, parents, providers, and advocacy organizations. From May through September 2025, the group:
Held four public listening sessions across the state and one statewide virtual session, hearing from nearly 60 Hoosiers.
Received over 170 written submissions from families, providers, and advocates.
Reviewed statewide utilization and cost data, national benchmarks, and best practices from other states.
Conducted a comprehensive review of quality, eligibility, utilization, reimbursement, provider oversight, and transitions.
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
The Working Group issued five interdependent recommendations to protect access, improve quality, and ensure sustainability:
Align ABA utilization with clinical evidence
Implement flexible service allocations (up to 4,000 hours of comprehensive ABA per child, followed by targeted ABA therapy).
Require caregiver involvement to reinforce ABA strategies across daily routines.
Tie the benefit explicitly to EPSDT (federal Medicaid standard for children).
Ensure high-quality care and optimal outcomes
Establish BCBA-to-RBT supervision ratios.
Require accreditation of ABA therapy centers.
Implement a temporary moratorium on new sites, while incentivizing providers to expand in underserved areas.
Establish sustainable rates
Adjust reimbursement rates for individual ABA therapy as deemed necessary to stay within the agency’s appropriated budget.
Create rate modifiers to encourage group therapy where clinically appropriate.
Explore future quality incentive payments to reward measurable outcomes.
Strengthen program management and oversight
Create a dedicated ABA program office within FSSA.
Improve transition planning.
Enforce accountability for providers by enhancing auditing, documentation, and compliance monitoring.
Support a sustainable ecosystem for ABA
Ensure commercial insurers reimburse ABA therapy above Medicaid rates.
Strengthen collaboration with schools to support smoother transitions and coordinated care.
Enhance state’s third-party liability (TPL) tracking methods to bill additional costs of ABA therapy to commercial insurers
Next Steps
The recommendations will move into the implementation phase, with FSSA working closely with providers, families, schools, and insurers to ensure a smooth transition.
“This is Indiana choosing thoughtful reform over arbitrary cuts,” said Secretary Mitch Roob. “We are protecting children and preserving access to ABA therapy for the children and families who depend on it.”