On June 2, the Indiana Family and Social Services Administration announced a temporary moratorium on the enrollment of new ABA provider agencies, effective June 6. CMS formally approved the request under 42 CFR 455.470 after determining that new ABA agency enrollments “represent a significant potential risk for fraud, waste, or abuse.”
The initial period is six months. It can be extended in six-month increments, with no stated limit on how many.
If you’ve followed our Indiana coverage, you knew this was coming. The moratorium was one of the five actions Secretary Mitch Roob announced in the closed-door March 24 meeting, alongside the April 3 self-reporting deadline, the 4,000-hour lifetime cap, the rate phasedown, and accelerated mandatory accreditation. The self-report window closed. The cap and rate changes took effect April 1. Piece by Piece Autism Centers shut all seven of its locations on May 15 after FSSA terminated its Medicaid agreements. Now the moratorium is live.
But one detail in the June 2 announcement got less attention than the enrollment freeze, and for some owners it matters more: the moratorium also pauses changes of ownership for existing agencies.
If you were planning to sell your Indiana practice, the exit door just closed. Minimum six months. Possibly longer.
What the moratorium actually covers
The June 6 rules, straight from the FSSA release:
- New ABA provider agency enrollments: paused. No brand-new agencies can enroll in Indiana Medicaid.
- Changes of ownership for existing agencies: paused. An acquirer can’t take over an existing agency’s enrollment.
- Individual rendering practitioners: still open. BCBAs and RBTs can continue to enroll. FSSA framed this as “preventing workforce disruption.”
- Applications received before June 6: processed as usual. If your paperwork was in before the effective date, it moves forward.
- Exceptions: available, but narrow. Accredited providers in underserved regions may request one through [email protected]. FSSA says it will monitor service access indicators throughout the period.
Deputy Secretary Eric Miller’s statement is the state’s clearest framing yet of where this is headed: “Indiana has seen an incredible surge in ABA spending over the past several years—a trend that raises concerns about sustainability and program integrity. This moratorium is a targeted, responsible step to ensure that growth in ABA services remains accountable and aligned with the needs of Hoosier families.”
The surge he’s referring to is the one we’ve covered since March: $21 million in Medicaid ABA spending in 2017, $611 million in 2023, nine of the nation’s top ten per-patient billers in one state. Indiana already cut spending 27% in a single year by replacing its 40%-of-billed-charges formula with a flat $68 hourly rate. The moratorium is the next lever: stop new entrants entirely while the state rebuilds its oversight.
One thing changed between the March announcement and the June order. In March, FSSA described a Florida-style moratorium targeting designated counties, modeled on the freeze AHCA imposed in Miami-Dade and Broward in 2018. The version CMS approved has no county limitation. It covers the whole state.
The ownership freeze is a six-month lock on M&A exits
Consolidation has been the default exit for ABA founders for a decade. A Medicaid-heavy practice’s sale price rests on one assumption: the buyer can step into your Medicaid enrollment and keep billing. In Indiana, that step is a change of ownership, and changes of ownership are now frozen.
Work through what that means in practice:
Deals in diligence stall. A buyer can sign whatever they want, but they can’t complete the enrollment transfer that makes the acquisition function. Closings built around a summer or fall 2026 transfer date need new timelines.
“Six months” is a floor, not a ceiling. The release says extensions come in six-month increments “as necessary.” Florida’s county-level freezes were renewed for years. Any owner pricing a sale should model a 2027 close, not a December 2026 one.
Buyers reprice Indiana risk. An acquirer choosing between a practice in Indiana and a comparable one in Ohio now sees regulatory timing risk on one side of the ledger. That pressure lands on valuation even after the moratorium lifts.
Pre-June 6 applications are the exception. If a change-of-ownership application was received before June 6, it processes normally. If your deal’s paperwork was in, confirm that with FSSA in writing. If it wasn’t, you’re waiting.
None of this is hypothetical for owners near retirement, owners facing the new rate environment, or owners who watched the Piece by Piece termination and decided the risk profile of staying independent had changed. Selling was the pressure valve. Indiana just shut it for at least half a year, during the same stretch when rate cuts and accreditation costs are squeezing margins.
August 1 is six weeks away, and there’s now one accreditation door
The moratorium is the enforcement stick for new entrants. For the agencies already enrolled, the binding deadline is accreditation.
Every currently enrolled ABA agency in Indiana must submit documentation by August 1, 2026 showing it has begun the accreditation process. Full accreditation is required by October 1, 2027. Two accrediting bodies qualify: the Autism Commission on Quality (ACQ) and the Behavioral Health Center of Excellence (BHCOE).
Those two bodies are now one organization. CASP, which runs ACQ, agreed in late December to acquire Jade Health, BHCOE’s parent company, and completed the deal on January 13. The combined program operates under the ACQ name and framework. Existing BHCOE accreditations stay valid, and BHCOE-accredited organizations transition to ACQ at their next reaccreditation cycle.
So while Indiana’s rule lists two qualifying accreditors, there is functionally one standard and one application pipeline for every ABA agency in the state facing the same deadline. Every enrolled agency, one queue, six weeks.
“Initiated” is a low bar compared to full accreditation. It means an application on file and evidence you’ve started. But it’s not something you produce the morning of August 1, and the documentation the full survey eventually demands (supervision records, outcomes data, incident reporting, clinical quality processes) takes months to assemble if it doesn’t already exist in your systems.
There’s a second reason accreditation matters right now: it’s the ticket for the moratorium’s only exception. FSSA will consider letting accredited providers enroll in underserved regions. Unaccredited providers have no path into Indiana at all. Accreditation went from a quality signal to the precondition for both staying and entering.
The playbook is complete, and it’s portable
Step back and look at the sequence:
- December 2024: HHS OIG publishes its Indiana audit, finding at least $56.6 million in improper ABA payments.
- March 10: The Wall Street Journal names Indiana the epicenter of ABA overbilling.
- March 24: Roob’s closed-door meeting. Five-part package announced, self-reporting demanded within ten days.
- April 1: Lifetime cap and rate phasedown take effect. FSSA moves to terminate Piece by Piece.
- May 15: Piece by Piece’s seven centers close.
- June 6: CMS-approved statewide moratorium on new agencies and ownership changes.
- August 1: Proof of initiated accreditation due from every enrolled agency.
- October 1, 2027: Full accreditation required.
Audit, self-report ultimatum, termination, moratorium, accreditation mandate. That’s the complete arc, executed from first headline to CMS-approved freeze in under three months.
And every tool Indiana used is available to every other state. 42 CFR 455.470 is federal regulation; any state Medicaid agency can request a moratorium, and CMS has now shown it will approve one for ABA specifically on fraud-waste-abuse grounds. Massachusetts already mandates accreditation. North Carolina’s legislature has an ABA Medicaid overhaul in motion. Nebraska capped hours and cut rates after its own spending spike. The states with 400%+ ABA spending growth curves all have the same OIG audit data and now a CMS-blessed precedent for freezing enrollment.
Indiana wrote the template. The only question for a Medicaid-heavy practice elsewhere is how much of it your state adopts, and when.
What to do now
If you’re an enrolled Indiana agency and haven’t started accreditation: start this week. You need documentation of an initiated process in FSSA’s hands by August 1. That’s an ACQ application, not a full survey, but application intake takes time and the whole state is converging on the same queue. Don’t budget on the assumption that a late-July submission clears.
Begin assembling survey evidence in parallel. ACQ’s framework covers clinical quality, supervision, outcomes monitoring, risk management, and patient safety. If your supervision logs, session documentation, incident reports, and outcomes data live in spreadsheets and binders, the gap between “initiated” and “accredited by October 2027” is bigger than it looks. Pull a sample month and try to produce, on demand: every supervision session with duration and signatures, mastery data for every active goal, and a complete audit trail for one client’s records. That’s roughly what a surveyor will ask for.
If you’re mid-sale or planning one, get healthcare counsel on the moratorium now. Confirm whether your change-of-ownership application was received before June 6. If not, restructure your timeline around a minimum six-month delay, and plan for extensions. Understand what your purchase agreement says about regulatory delay before your buyer’s counsel does.
If you’re an out-of-state provider with Indiana expansion plans, the exception path is your only path. It requires accreditation and a demonstrated access gap in an underserved region. Requests go to [email protected]. If you’re not accredited, Indiana is closed to you for the duration.
Keep hiring. Practitioner-level enrollment continues. Growing your clinical team inside an existing agency enrollment is unaffected.
If you’re outside Indiana, treat this as your preview. Pull your per-patient billing against state norms, audit your documentation against the OIG’s published failure categories, and start accreditation before your state makes it mandatory on six weeks’ notice. Indiana’s agencies got their accreditation deadline with less lead time than it takes to complete the process. Yours may too.
Accreditation surveys and Medicaid audits ask for the same thing: show your work. StreamABA keeps that evidence as a byproduct of running your practice – supervision compliance dashboards, outcomes and mastery data on every goal, and audit trails on every record. If August 1 made you realize your documentation lives in too many places, reach out at [email protected].
Sources
- Indiana FSSA: Indiana Announces Temporary Moratorium on New ABA Provider Agency Enrollments (June 2, 2026)
- The Arc of Indiana: ABA accreditation requirements
- CASP: CASP and Jade Health/BHCOE
- 42 CFR 455.470: Temporary moratoria on enrollment of new providers
- HHS-OIG: Indiana Made at Least $56 Million in Improper Fee-for-Service Medicaid Payments for ABA (December 2024)
