Indiana Medicaid Waiver Changes Coming in 2025: What Families Need to Know

Indiana’s Medicaid waiver system is undergoing major redesign—changes that begin rolling out in January 2025 and continue through the larger 2025–2026 Waiver Reset. If you or your loved one relies on home- and community-based services (HCBS), these updates may significantly affect the supports you receive.

Below is a clear breakdown of what’s changing, what families need to watch for, and how you can make your voice heard during the public comment period.

Major Changes Beginning January 2025

1. Quarterly Bucket of Units

Starting Jan. 1, 2025, individuals will receive quarterly buckets of units instead of annual ones.

This means:

• Units expire every quarter if not used.

• Planning and scheduling will matter more than ever.

• Families who pace services slowly or experience unexpected gaps could lose unused support.

2. Behavioral Support Service Redesign

The state is restructuring behavioral services, including:

• Eliminating certain high-intensity interventions

• Requiring new standardized templates for FBAs, BSPs, and quarterly reports

• Potentially reducing the level of support available for individuals with complex needs

• For families with individuals who have complex behavioral, mental health, or dual-diagnosis needs, this may raise concerns about:

  • service quality

  • safety

  • consistency

  • appropriate clinical oversight

• Clinical supervision is now voluntary for unlicensed clinicians (Nowhere else can unlicensed providers bill Medicaid for therapeutic services without clinical oversight).

• Supervision can now be provided by master’s-level clinicians—not just doctoral-level providers. (This is a significant shift from the previous requirement that only PhD- or PsyD-level providers could supervise behavioral clinicians).

• The state is also considering replacing master’s-level clinicians with bachelor’s-level staff. (This proposal, if adopted, would dramatically change the qualifications required to provide behavioral services.

• New state templates were released this week and must be used moving forward.

3. Changes to Caregiver Support

Indiana is proposing:

• A 40-hour weekly cap on paid family caregiver (PFC) services

• Stricter rules about paying guardians or household members

• More required documentation for justification

4. New Eligibility Assessments for Children (July 2025)

FSSA is adopting new tools for determining children’s level-of-care eligibility.

Advocates fear this may reduce waiver access for some children who previously qualified.

Why These Changes Matter

Families may face:

• Reduced access to experienced clinicians

• More rapid turnover due to qualification changes

• Lost services when quarterly units expire

• Decreased support for individuals with high behavioral needs

• Pressure on caregivers due to capped hours

• Eligibility challenges for children

These changes affect daily functioning, stability, crisis prevention, family well-being, and long-term safety.

Your Voice Matter

Families and providers directly affected by the waiver system are the most important voices in this process.

If you rely on behavioral supports, caregiver services, or mental health-informed care, this is the time to share your concerns.

Below is an easy-to-use comment letter template.

Letter Template (Copy & Personalize)

Subject: Public Comment on Indiana Medicaid Waiver Amendments

Dear FSSA,

I am writing to provide public comment on the proposed changes to the Medicaid waiver. I am a (parent/caregiver/provider/advocate), and I am deeply concerned about how these changes may affect individuals with disabilities and their families.

My primary concerns include:

• The shift to quarterly units, which may cause individuals to lose services if units expire before they can be used.

• The reduction or elimination of intensive behavioral supports for individuals with complex needs.

• The proposed limitations on paid family caregivers, which may destabilize households reliant on consistent care.

• The new eligibility assessments for children, which may disqualify those who still require significant support.

• The removal of mandatory clinical supervision and the possibility of lowering provider qualifications from master’s-level to bachelor’s-level, which raises serious concerns about safety, quality of care, and appropriate intervention for people with higher needs.

I respectfully ask FSSA to consider the real-world impact these changes will have on vulnerable Hoosiers and their families.

Thank you for your time and consideration.

Sincerely,

[Your Name]

[City, Indiana]

We’ll Keep You Updated

At Booth & Company, we are committed to helping families understand these changes as they unfold. We will continue to share updates, resources, and guidance to help you navigate Indiana’s evolving Medicaid landscape.

If you have questions or need help understanding how these changes may affect you or your family, we’re here to help.