Indiana's ABA Accreditation Deadline Passed August 1. The Penalty Is Deactivation.

If you run an ABA agency enrolled with Indiana Medicaid, there was a date a month ago you needed. From bulletin BT202646, issued March 26, 2026:

“All documentation must be received by Aug. 1, 2026. Failure to provide documentation will result in the enrollment being deactivated.”

The documentation is proof that the agency has initiated accreditation — not that it holds it. Full accreditation is due by October 1, 2027, and agencies must “remain actively accredited” after that to stay enrolled.

The two accreditors are now one company

Indiana recognizes accreditation from the Autism Commission on Quality (ACQ) and the Behavioral Health Center of Excellence (BHCOE). Those read as two options. They are not.

ACQ is the accreditation body of the Council of Autism Service Providers, launched in 2022. In late December 2025, CASP agreed to acquire BHCOE and the other holdings of Jade Health, announcing it in January. CASP's own account of what follows is explicit: “Once fully unified, the combined non-profit accreditation efforts will operate under the ACQ name and framework.” Existing BHCOE accreditations stand, and organizations move to applying through ACQ when they reaccredit.

Indiana's bulletin carries the same instruction in a footnote most readers will have skipped: “Any previous accreditation issued from BHCOE will be accepted until an agency's reaccreditation with ACQ.”

So the state has made accreditation a condition of Medicaid enrollment, named two accreditors, and both belong to the trade association that represents the providers being accredited. CASP has said its reason for buying was to protect providers who had already invested in accreditation from losing the value of it. That is the structure; what you make of it is yours.

And you cannot sell your way out

Bulletin BT202692, June 4, 2026, reports that CMS approved Indiana's request for a provider enrollment moratorium on ABA providers, effective June 6, 2026 for an initial six months, which the IHCP “may continue to extend in six-month increments.”

• It blocks brand-new ABA group enrollments.
• It blocks changes of ownership for existing ABA therapy agencies — which is the sentence that matters if you were planning to sell, merge, or restructure.
• It does not apply to rendering provider enrollment for individuals delivering ABA.
• Exceptions exist for member access in areas of need — and to qualify for one, “provider agencies seeking an exception to the moratorium must be accredited per the requirements described in IHCP Bulletin BT202646.”

Read those two bulletins together and accreditation stops being a quality badge. It is the gate on staying enrolled, and the only key to the exception process for a moratorium that also freezes the exit.

The limits

The initial six-month moratorium period runs to around December 6, 2026, and the IHCP has told nobody whether it will extend. The bulletins do not say how quickly a deactivated enrollment can be reinstated, or whether an agency that missed August 1 but has since started accreditation is treated differently from one that never began. Neither document sets a price for accreditation. And ACQ and BHCOE remain separately listed as recognized bodies today — the consolidation is announced, not complete.

What you must know or do

• Owners in Indiana: check your enrollment status on the IHCP Provider Healthcare Portal today. Deactivation from the August 1 miss would be showing up now, and a deactivated enrollment does not announce itself — you find it on a denied claim.
• If you did submit: confirm it arrived. The bulletin names one address, INXIXabaenrollments@gainwelltechnologies.com, or an upload through the portal as a provider maintenance update. An email with no reply is not evidence of receipt.
• If you missed it: start accreditation and contact the IHCP now rather than waiting. October 1, 2027 requires a completed process, and accreditation takes most organizations two to three quarters — so the runway is shorter than the date suggests.
• If you were planning to sell or bring in a partner: a change of ownership is blocked while the moratorium runs. Get accredited first, because accreditation is the stated condition of even being considered for an exception.
• Everyone else: Indiana is the first state to make accreditation a condition of Medicaid enrollment and then pair it with an enrollment freeze. Massachusetts already requires accreditation, and a commercial plan across five New England states starts requiring it on January 1, 2027. If your state is drafting, this is the template it will be handed.