Indiana Just Told ABA Providers How to Handle Naps, Referrals, and FBAs. The FBA Deadline Is October 29.

Three Bulletins, One Afternoon

On September 29, the Indiana Health Coverage Programs (IHCP) published three ABA bulletins at once:

• BT2026159: a policy on sleeping and naps during ABA therapy
• BT2026160: a clarification of statement of need and referral requirements
• BT2026162: a requirement for functional behavior assessments behind every behavior intervention plan, effective October 29, 2026

They arrived two days before Indiana’s adult cutoff took effect. Under BT202627, published in February, the IHCP stops authorizing or paying for ABA for members 21 and older for dates of service on or after October 1, 2026.

If you’ve followed Indiana this year, you know the pattern. The 10-day self-reporting window in March, the first provider exit in April, and the enrollment moratorium in June. These new bulletins are quieter than any of those, but they reach further. They change what goes into every treatment plan, every prior authorization packet, and every BIP in the state.

Here’s what each one requires and what to do about it.

BT2026159: Naps Go on the Schedule

The bulletin opens with its reason. The IHCP says it “has observed media reports that members receiving applied behavior analysis (ABA) therapy services are only permitted to nap for seven minutes at a time, if at all.”

The core rule: providers must follow American Academy of Pediatrics sleep recommendations for the child’s age, in coordination with parents, and “members must not be prevented from napping during ABA therapy hours due to it being nonbillable time.”

The specific requirements:

• Nap time goes in the treatment plan. Necessary nap time based on age must be included in the schedule of services.
• Medical sleep issues need coordination. If comorbid diagnoses or medical issues affect sleep, the provider must coordinate with the child’s primary care provider and parents and document the result in the treatment plan.
• Home sleep problems get evaluated. If you and the family identify sleep routine or hygiene issues, document them and evaluate whether caregiver coaching goals are needed.
• Mid-authorization changes must be documented in detail. If naps weren’t needed when you requested 97153 hours but become necessary later, the treatment plan must record the nap duration, the date naps became a consistent need, every date the duration changed, and the date naps stopped. The bulletin also requires “robust documentation” explaining lower 97153 utilization due to naps.
• No forced waking. Children can’t be kept awake or woken by physically moving them, forcing activities, tickling, or similar. They may be woken after the AAP-appropriate duration, but not physically moved to do it.
• Repeated send-homes mean a schedule change. If a child is repeatedly sent home for naps or keeps exceeding recommended nap time, you and the family must work out a more appropriate schedule, adjust hours, and document it.

That fourth bullet is the one with money attached. Utilization is one of the first things payers look at when they cut hours at renewal. Indiana is telling you exactly how to explain an authorization that came in under its hours because a child needed sleep. If the dates and durations aren’t in the plan, the shortfall reads as missed sessions.

What to do now:

1. Pull every Indiana Medicaid client young enough that the AAP recommends naps. Check whether each treatment plan’s schedule of services includes nap time.
2. For any client whose naps started, grew, or stopped during the current authorization, add the dates and durations to the plan now, not at the next renewal.
3. Write a short internal policy on waking and send-homes that matches the bulletin, and train RBTs on it. The forced-waking rule is the kind of thing a parent complaint turns into a site visit.

BT2026160: Who Can Write a Referral, and When You Need One

This bulletin cleans up an old point of confusion. Earlier bulletins (BT202562 and BT202519) required a statement of need along with a referral when the child’s comprehensive diagnostic evaluation (CDE) was more than a year old. Going forward, “statement of need” and “referral” mean the same thing.

Who can write one: only a referring practitioner with specialized training in current DSM autism criteria, from this list:

• Doctoral-level licensed clinical psychologist endorsed as a health service provider in psychology (HSPP)
• Licensed physician
• Licensed advanced practice registered nurse (APRN)
• Licensed physician assistant

Who can’t: a BCBA, BCaBA, physical therapist, speech-language pathologist, or occupational therapist. If your practice has had BCBAs drafting these for a pediatrician’s signature, make sure the signature belongs to the qualified practitioner and that practitioner actually reviewed it.

When you need one:

• At the start of ABA services, if the CDE is more than one year old
• At reauthorization, when a child already in services has a CDE that has just passed one year old
• With a new prior authorization after a six-month gap in ABA services, and again with each new PA if the gaps keep happening

When you don’t: not with every reauthorization, and not annually. Once a referral is submitted for one of those scenarios, it doesn’t need to be resubmitted. Reassessment and an updated treatment plan are still required at least every six months.

The content is flexible. A referral may describe current skill deficits or target behaviors from the three months before treatment, with examples, but the bulletin says that’s not required.

What to do now:

1. Add each Indiana client’s CDE date to your intake and authorization records if it isn’t there already.
2. Set a reminder ahead of each reauthorization where the CDE will cross the one-year mark, so the referral request goes out before the PA is due rather than after it’s denied.
3. Flag any client returning after a six-month gap as needing a referral before you submit the new PA.

BT2026162: No BIP Without an FBA, Starting October 29

This is the bulletin with a deadline. The IHCP says it “has received reports that behavior intervention plans (BIPs) have been included in applied behavior analysis (ABA) therapy treatment plans that do not include a functional behavior assessment (FBA).” Effective October 29, 2026, it will require “a complete FBA for each behavior targeted by a BIP.”

The bulletin cites the BACB Ethics Code for Behavior Analysts (2.08, 2.09, 2.13 through 2.18, and 3.12) and calls the FBA standard clinical practice. Most BCBAs would agree. What’s new is that Indiana now specifies the documentation.

Required FBA components when a BIP is present:

• At least one function-based indirect assessment with a parent, guardian, or RBT, chosen from: Questions About Behavioral Function (QABF), Functional Analysis Screening Tool (FAST), Motivation Assessment Scale (MAS), Motivating Analysis Rating Scale (MARS), Problem Behavior Questionnaire (PBQ), or the Functional Analysis Interview (FAI). Results must be graphed, and the original responses included.
• ABC data (antecedent, behavior, consequence) for the target behavior
• Triggers and precursors to the target behavior, if applicable
• A hypothesized function statement that references the indirect assessment results and the ABC data

The FBA must be updated at every reauthorization: new indirect assessment results, recent ABC data, current triggers and precursors, and a revised function statement. A one-time FBA from intake won’t satisfy this.

A full functional analysis is still up to the provider. If you run one, the tools and results go in the treatment plan along with the required FBA documentation.

Required BIP components:

• An operational definition of the target behavior, with examples, non-examples, and offset criteria, defined by function and/or topography
• Precursor behaviors if applicable, with de-escalation procedures for when they occur
• Antecedent interventions that include functionally equivalent replacement behaviors taught or used proactively
• Consequence interventions that include functionally equivalent replacement behaviors taught or used reactively

The BIP must be updated when the behavior’s function changes, when interventions stop working, or when a new FBA yields a different result.

What to do in the next four weeks:

1. Inventory every active BIP for Indiana Medicaid clients. For each targeted behavior, confirm there’s an FBA on file with all four components. Don’t skip the graphed indirect assessment or the original responses.
2. Triage by reauthorization date. Clients whose next PA lands soonest after October 29 come first, because that’s when an incomplete FBA will surface.
3. Check BIPs against the component list. Missing offset criteria and missing replacement behaviors in the consequence section are the gaps we’d expect to find most often.
4. Build the reauthorization update into your workflow. If refreshing the FBA isn’t a step in your renewal checklist, it will get missed in the first busy month.

The Pattern: Indiana Is Writing the Treatment Plan Checklist

Read together, the three bulletins share a theme. Each takes something a careful BCBA would already do (protect a child’s sleep, get a valid referral, identify function before intervening) and turns it into a documented, auditable requirement.

That matches the direction of the CMS ABA toolkit released in August, which encouraged states to specify documentation and clinical standards in their ABA benefit design. Indiana is doing that one bulletin at a time. Other states that read the toolkit will copy what works.

The practical lesson for a practice outside Indiana is the same: if a payer asked tomorrow for the FBA behind every BIP, or the dates behind every utilization shortfall, could you produce them in an afternoon?

Where Software Fits

These requirements come down to treatment plans that are complete and records that are easy to find.

In StreamABA, treatment plans and behavior intervention plans live on the client record with review and signing workflows. Authorization tracking shows units used against units approved, with pace and exhaustion projections, so a nap-driven shortfall is visible mid-authorization while there’s still time to document it. Payer-specific document requirements and secure document request links help you collect a referral from the right practitioner before a PA is due.

None of that writes the FBA for you. That’s clinical work. What a system can do is make sure the plan, the referral, and the authorization are in one place when Indiana asks.

Running an Indiana ABA practice and want a second set of eyes on your BIP inventory? Reach out at [email protected].

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Sources

• IHCP Bulletin BT2026159: IHCP announces policy for sleeping and naps during ABA therapy (September 29, 2026)
• IHCP Bulletin BT2026160: IHCP clarifies ABA therapy requirements related to statement of need and referrals (September 29, 2026)
• IHCP Bulletin BT2026162: IHCP requires functional behavior assessments for ABA therapy and behavior intervention plan (September 29, 2026)
• IHCP Bulletin BT202627: IHCP announces changes to applied behavior analysis (ABA) therapy services (February 26, 2026)
• IHCP Bulletins index