Indiana Will Require a Complete FBA for Every Behavior a BIP Targets From October 29

IHCP bulletin BT2026162 lists the indirect assessments, ABC data and function statement it expects, and requires the FBA to be updated at every reauthorization.

Indiana Health Coverage Programs issued bulletin BT2026162 on September 29: “Effective Oct. 29, 2026, the IHCP will require a complete FBA for each behavior targeted by a BIP.” That's 24 days from today. The IHCP says it acted on reports of ABA treatment plans carrying behavior intervention plans with no FBA behind them.

The turn: it's per behavior, and it's not one-time

An FBA on file for the case won't cover it. The requirement attaches to each behavior a BIP targets, and the FBA “must be updated with new function-based indirect assessment results, recent ABC data, identified triggers and precursors … and hypothesized function statement … for each reauthorization.” For a plan with four target behaviors, that's four documented FBAs refreshed every authorization period.

What the bulletin requires

  • At least one indirect assessment with a parent/guardian and/or RBT, from a closed list: QABF, FAST, MAS, MARS, PBQ or the Functional Analysis Interview. Results “must be compiled in a visual graph, and original … responses included.”
  • ABC data for the target behavior.
  • Triggers and precursors, if applicable.
  • A hypothesized function statement referencing the indirect assessment and ABC data.

The BIP must then carry an operational definition with examples, nonexamples and offset criteria, and antecedent and consequence interventions that each include functionally equivalent replacement behaviors. When the function changes or interventions stop working, the BIP must be updated.

A functional analysis stays the provider's call: “It is up to the discretion of the provider to identify when a functional analysis (FA) is necessary.” If you run one, its tools and results go in the treatment plan in addition to the FBA. The bulletin cites Ethics Code items 2.08, 2.09, 2.13 through 2.18 and 3.12.

The limits

The bulletin doesn't say whether plans authorized before October 29 must be brought up to standard immediately or at their next reauthorization, or what a reviewer will do with a plan that falls short. It names the indirect tools but sets no minimum amount of ABC data. It's one of four ABA bulletins Indiana published the same day, alongside a nap policy and the end of fee-for-service peer-to-peer reviews.

What you must know or do

  • Clinical directors: pull every active Indiana Medicaid plan with a BIP. For each target behavior, check for an indirect assessment from the six named tools, a graph with the raw responses attached, ABC data and a function statement. Anything missing is a gap to close before October 29.
  • BCBAs: if your FBA template uses an indirect tool that isn't on the list, add one that is.
  • Owners: add the per-behavior FBA refresh to your reauthorization checklist and budget the 97151 time it takes. Ask your Indiana plans in writing whether existing authorizations are reviewed against this at the next renewal or sooner.