The Indiana Health Coverage Programs (IHCP) has received approval from the Centers for Medicare & Medicaid Services (CMS) to implement a statewide provider certification and enrollment moratorium on home- and community-based services (HCBS) 1915(c) waiver providers. This will encompass services falling under the Indiana PathWays for Aging (PathWays), Health and Wellness (H&W), Traumatic Brain Injury (TBI), Community Integration and Habilitation (CIH) and Family Supports (FS) waivers.
The effective date for the moratorium is Aug. 1, 2026. This moratorium will be in place for an initial period of six months. The IHCP may continue to extend the moratorium in six-month increments.
The following 1915 (c) waiver services are subject to the moratorium:
- Adult Family Care
- Attendant Care
- Behavior Management
- Behavior Program and Counseling
- Caregiver Coaching
- Day Habilitation
- Extended Services
- Facility-Based Support
- Family and Caregiver Training
- Home and Community Assistance
- Home-Delivered Meals
- Music Therapy
- Participant Assistance and Care
- Personal Emergency Response System
- Recreational Therapy
- Rent and Food for Unrelated Live-In Caregiver
- Residential-Based Habilitation
- Residential Habilitation and Support – Daily and Hourly
- Respite
- Respite Care Services
- Structured Family Caregiving
- Transportation
- Wellness Coordination
- Workplace Assistance
Under Code of Federal Regulations 42 CFR 455.470, a state Medicaid agency can impose a temporary moratorium on the enrollment of new providers that the agency identifies as having a significant risk for fraud, waste or abuse, and that the Secretary of the U.S. Department of Health and Human Services (HHS) has identified as being at high risk for fraud, waste or abuse.
Applications for waiver certification for H&W, PathWays and TBI waivers currently under review in the Office of Medicaid Policy and Planning (OMPP) HCBS Certification Portal will be processed. Any applications currently awaiting review or new applications will be expired. Expired applicants may reapply after the moratorium has been lifted.
Certification applications for CIH and FS waivers currently under review will be expired, and providers will be allowed to reapply after the moratorium has been lifted. Applications that are in provisional approval status will be held until the moratorium period ends.
All screening requirements for IHCP enrollment must be completed prior to Aug. 1, 2026, to be enrolled during the moratorium period. Any open enrollment applications that have not completed screening requirements prior to Aug. 1, 2026, will be denied and applicants may reapply after the moratorium has been lifted.
The moratorium will prevent certification and enrollment for certain waiver services as well as changes of ownership, adding counties and adding services subject to the moratorium for existing HCBS agencies.
The moratorium will not apply to the following services:
- Adult Day Services
- Assisted Living
- Case/Care Management
- Benefits Counseling
- Career Exploration and Planning
- Community Transition
- Home Modification and Assessment
- Integrated Health Care Coordination
- Nutritional Supplements
- Occupational Therapy
- Pest Control
- Physical Therapy
- Prevocational Services
- Psychological Therapy
- Remote Supports
- Specialized Medical Equipment and Supplies
- Speech/Language Therapy
- Structured Day Program
- Supported Employment
- Vehicle Modifications
The IHCP will consider limited exceptions to the moratorium to ensure sufficient member access to waiver services to areas in need. Provider agencies seeking an exception to the moratorium must meet all provider qualification requirements for service provision. Providers are required to submit a narrative explaining how the provider’s exception request can address an access concern.
Providers and applicants may submit their request for an exception by emailing OMPPProviderRelations@fssa.in.gov.
