Indiana Made at Least $56 Million in Improper Fee-for-Service Medicaid Payments for Applied Behavior Analysis Provided to Children Diagnosed With Autism

Date Issued

Monday, December 16, 2024

Submitting OIG

Department of Health & Human Services OIG

Agencies Reviewed/Investigated

Department of Health & Human Services

Report Number

A-09-22-02002

Report Type

Audit

Agency Wide

Yes

Number of Recommendations

Questioned Costs

Funds for Better Use

Report updated under NDAA 5274

External Link

https://oig.hhs.gov/reports/all/2024/indiana-made-at-least-56-million-in-improp…

Open Recommendations

This report has 5 open recommendations.

Recommendation Number	Significant Recommendation	Recommended Questioned Costs	Recommended Funds for Better Use
25-A-09-026.01	No	$0	$0
We recommend that the Indiana Family and Social Services Administration refund $39,432,556 (Federal share) to the Federal Government for FFS Medicaid ABA payments that did not comply with Federal and State requirements.
25-A-09-026.02	No	$0	$0
We recommend that the Indiana Family and Social Services Administration provide additional guidance to ABA facilities for documenting ABA, including services that must be provided to support the use of CPT codes 97155 and 97156, State signature requirements, the detail in session notes needed to support ABA provided, and what the State agency considers billable ABA time.
25-A-09-026.03	No	$0	$0
We recommend that the Indiana Family and Social Services Administration periodically perform a statewide postpayment review of Medicaid ABA payments, including reviewing medical records, to educate providers on requirements and to recover payments that did not comply with Federal and State requirements.
25-A-09-026.04	No	$0	$0
We recommend that the Indiana Family and Social Services Administration periodically review its prior authorization contractor's procedures for verifying ABA facilities' compliance with requirements for State diagnostic evaluations and treatment referrals for ABA.
25-A-09-026.05	No	$0	$0
We recommend that the Indiana Family and Social Services Administration exercise reasonable diligence to review and determine whether any of the estimated $53,236,026 (Federal share) in potentially improper ABA payments complied with Federal and State requirements and refund the Federal share of any improper payment amount to the Federal Government.