Indiana Medicaid Proposed Devastating Changes for ABA Families

On Dec 17th, 2024, during the State Budget Committee, Medicaid announced the following proposed changes for their coverage of ABA therapy:

1. 30-hour weekly limit on ABA services per child.

2. Three-year maximum for ABA services per child.

3. Credentialing for all RBTs - excessive compared to industry standards, certain to cause extensive delays in services and further backlog waitlists.

ABA therapy is the most effective, evidence based treatment for children on the autism spectrum. These changes will harm children who rely on ABA Therapy and will violate the federal Mental Health Parity and Addiction Equity Act (MHPAEA) which prohibits time caps for ongoing conditions.

Why Will These Medicaid Changes to ABA Coverage Be So Devastating If Enacted?

1. Time and consistency are critical in the successful delivery of ABA therapy.

   1. The majority of children receiving ABA therapy rely on more than 30 hours a week. This is based on assessment of medical necessity by their healthcare provider. Arbitrarily reducing their hours to 30 without medical reasoning or behavioral data reduces the effectiveness of ABA therapy. This goes against the data-driven principles that guide all ABA decisions.

   2. At best, clients with reduced hours will need to remain in ABA longer to achieve the same results (time which they won't have because of the second change). At worst, reduced time will halt progress or even cause progress to backslide.

2. Arbitrarily limiting all children to no more than 3 years of coverage without evaluating their need is illogical and incredibly harmful.

   1. All children learn at different paces. This is even more dramatically apparent for children on the autism spectrum. But slow steady progress is far different from no progress. Just because a child is moving "slowly" through goals according to neurotypical standards does not mean ABA therapy has failed or that the child is not receiving a vital service.

   2. ABA therapy is critical in preventing an increase in behavioral issues that would arise if the child was not receiving intervention. This is clear from both behavioral data and family testimony when ABA is halted unexpectedly.

   3. Children must be carefully transitioned out of ABA therapy in order for success to be maintained across other environments. This transition can only happen when children have mastered the necessary skills. If ABA therapy ends suddenly and prematurely, it will be incredibly disorienting for the child, and a loss of skills will occur.

3. Credentialing requirements are in excess of industry standards and will lower the timeliness of care.

   1. These will add months to the time a child will spend on waitlists. This delay in services will harm children and is in violation of EPSDT, which says children should have immediate access to medically necessary care.

   2. Furthermore, since this gap in average wait-time is based on financial source, this will amplify socio-economic disparities in access to medically necessary services.

Medicaid Disregards Data, Protocols, and Federal Requirements

These time limits were selected by individuals who are not BCBAs and not qualified to recommend a reduction in hours for any client. They fly in the face of the data-driven practices that make ABA therapy effective.

Furthermore, Medicaid made these announcements without following standard protocol of soliciting input from families or providers. In violation of the rulemaking procedures set forth by ODM, there was no public comment period or public hearing for these proposed time caps and requirement increases.

For more information on how these proposed changes violate federal requirements, go here.

Changes Ignore the Long-Term Economic Impact

If these changes are enacted, it will cause negative ripple effects throughout our state for years to come. These children will not be able to be fully active, engaged participants in their community without the ABA therapy they need.

The proposed limits will increase costs for the state in the future, not decrease them. By not providing the appropriate treatment now, the state will pay more later for more complex and costly services.

Help Children Be Heard - Prevent These Changes in Medicaid Coverage of ABA

As is often the case with disability rights and medical access, decisions are being pushed through without consulting those who would be affected. But you can help their voices be heard. Send a template letter of your choice to legislators. You will be able to edit your letter template if you wish.