New requirements begin October 29, 2026
The Indiana Health Coverage Programs (IHCP), which administers Indiana Medicaid programs, is introducing new requirements for applied behavior analysis (ABA) therapy when a behavior intervention plan is used. The goal is to help ensure that behavior interventions are based on an assessment of why a behavior occurs.
What is changing?
Beginning October 29, 2026, providers must complete a functional behavior assessment (FBA) for each behavior addressed in a behavior intervention plan (BIP).
An FBA helps providers understand what may trigger a behavior and what purpose the behavior may serve. This information helps providers develop strategies that address the behavior and teach alternative behaviors that meet the same need.
The assessment must include information about the behavior, including data about what happens before and after it, possible triggers, and the provider's explanation of the behavior's likely function.
What does this mean for families?
A behavior intervention plan should reflect the assessment findings. The plan must include strategies to help prevent or respond to behaviors and teach alternative behaviors. When appropriate, it should also address early signs of behavior and ways to help de-escalate situations.
Providers must update the assessment with new assessment results and recent behavior data at each treatment-plan reauthorization. The behavior intervention plan must also be updated when the behavior's function changes, interventions become ineffective, or new assessment results identify a different function.
What should you do?
If your child receives ABA therapy, you may want to talk with your provider about how your child's behaviors are assessed and how those findings guide the treatment plan. The bulletin establishes requirements for providers; it does not specify that families must complete a new application or take a particular action.
The bulletin also does not state that children must stop receiving ABA therapy because of these changes.
Questions? Contact Indiana Health Coverage Programs Customer Assistance at 800-457-4584.
*Source: Indiana Health Coverage Programs, Bulletin BT2026162, September 29, 2026.*
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