Indiana Medicaid · Deep Dive

A study by Luminary AI Technologies for the Indiana FSSA — a current-state read on the infrastructure, workflows, stakeholder experiences, verification A study conducted by Luminary AI Technologies for the Indiana FSSA — every zone, every step, the operational reality, with peer-state context. eligibility processes, integrity surface, encounter pipelines, and other variables that shape Indiana Medicaid today.

LUMINARY AI TECHNOLOGIES · PREPARED FOR THE INDIANA FAMILY AND SOCIAL SERVICES ADMINISTRATION · MAY 2026

This is the deep-dive companion to the master system map. For each of the 10 publicly-focused heat zones and each of the 11 end-to-end process flows, we draw the operational reality at the step level: named owner per step, named handoff, where it actually breaks, and — explicitly — what we don't know yet. The diagnosis prose for each section is the synthesis. The "What we don't know yet" callouts are the questions Luminary would bring to FSSA in any first working session.

H1HEAT ZONE

Eligibility documentation surface

The renewal & verification workflow that produced the 78% procedural disenrollment rate — now carrying H.R. 1 quarterly, SB 1 quarterly, and EO 25-60 end-of-self-attestation simultaneously.

STEP 1
Application or renewal trigger fires
OWNER
IEDSS scheduler + DFR
HANDOFF
Into IEDSS workflow queue
WHERE IT BREAKS
Four schedules now running on overlapping populations: 12-mo MAGI renewal · 12-mo non-MAGI renewal · H.R. 1 quarterly work-req check (HIP) · SB 1 quarterly verification. Same member may face 3+ events per year.
WHAT WE DON'T KNOW
How many Hoosiers fall in multi-schedule overlap; no FSSA disclosure of intersection volume.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
Ex parte attempt against existing data
OWNER
IEDSS rules engine (Deloitte)
HANDOFF
Federal Data Services Hub (IRS · SSA · USCIS SAVE · Equifax) + DWD wage feed
WHERE IT BREAKS
Ex parte success rate not public. National post-PHE ex parte rate ~41% (KFF). If Indiana is at the national rate, ~59% of renewals enter the human-touch funnel.
WHAT WE DON'T KNOW
Indiana's specific ex parte success rate; which data sources IEDSS queries for cash/gig/self-employment income.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
North Carolina achieves 99% ex parte success — among the highest in the nation — using SSA + IRS + state wage data on auto-renewal. NC final procedural disenrollment rate during the unwinding: 12% (Indiana: 78%). Aggressive automation, not more staffers, drives the gap. Arizona and New Mexico also have data-driven ex parte models. — KFF · NC Medical Society · NC Health News
STEP 3
Pre-populated renewal form generated (if ex parte fails)
OWNER
IEDSS form module
HANDOFF
USPS mail + portal notification if opted in
WHERE IT BREAKS
Mail-based renewal is the dominant channel; address staleness is a known national driver of procedural disenrollment.
WHAT WE DON'T KNOW
Portal opt-in rate; address-change reconciliation cadence with USPS NCOA; mail-return rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Member responds via one of five channels
OWNER
Member, optionally with navigator (FQHC, certified counselor)
HANDOFF
Response routes to IEDSS document store or DFR call center
WHERE IT BREAKS
Phone channel capped by DFR call center capacity. Online channel limited by digital literacy + bandwidth in rural counties. Paper-by-mail channel slowest, no read receipt.
WHAT WE DON'T KNOW
Per-channel response rate; median response time; channel split by demographic.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Documents uploaded (income proofs, ID, residency, etc.)
OWNER
Member
HANDOFF
IEDSS document store; reconciliation queue for DFR caseworker
WHERE IT BREAKS
This is the step where the 78% procedural disenrollment rate concentrates: missing uploads, wrong document type, image quality, mismatch between uploaded doc and requested item.
WHAT WE DON'T KNOW
Per-document-type rejection rate; share of disenrollments from doc-mismatch vs no-response; CV/OCR usage in document classification.
PUBLIC COMMENT
March 2024 — of 9,608 Hoosiers terminated procedurally, 4,500 simply did not respond and FSSA had no other data; 2,748 didn't respond but were determined ineligible through other data; 2,360 provided incomplete information. Indiana's procedural-disenrollment rate held at 78% versus a national 69%. — Indiana Capital Chronicle · KFF unwinding tracker · May 2024
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Caseworker reconciles documents to IEDSS request
OWNER
DFR caseworker (one of ~92 county offices)
HANDOFF
Back to IEDSS verification step or to member for re-submit
WHERE IT BREAKS
Queues vary by county; 400 new eligibility checkers being added (50 onboarded by late April 2026); workflow itself unchanged. Adding humans to an unchanged workflow is the most expensive way to learn the bottleneck is procedural.
WHAT WE DON'T KNOW
Per-county queue depth; new-staffer training completion rate; per-staffer throughput targets.
PUBLIC COMMENT
FSSA is hiring 400 employees to check eligibility of 560K HIP enrollees ahead of H.R. 1 work requirements — 50 onboarded as of late April 2026. — Indiana Capital Chronicle · WTHI · Apr 29, 2026
OTHER STATES
Few states publish per-county DFR queue depth — but NC's ePASS consolidates Medicaid + SNAP + TANF + Child Care into a single statewide workflow, removing the per-county variability Indiana's 92-county DFR model carries. — NC DHHS ePASS
STEP 7
Income & data re-verification
OWNER
IEDSS
HANDOFF
Federal Data Services Hub + DWD
WHERE IT BREAKS
DWD wage data lags ~1 quarter behind real time. Self-employment, gig, and cash income largely invisible to DWD. EO 25-60 ended self-attestation — so where DWD has no record, members must produce documentation, raising the manual proof burden.
WHAT WE DON'T KNOW
% of members with income not coverable by DWD/FDH; manual proof completion rate.
PUBLIC COMMENT
EO 25-60 'Make Indiana Healthy Again' ended self-attestation and mandates interagency data matching to flag ineligible enrollees. — Governor's Office · EO 25-60 · Apr 15, 2025
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
MAGI / non-MAGI rules re-evaluate eligibility
OWNER
IEDSS rules engine (Deloitte; Cúram lineage)
HANDOFF
Internal — produces eligibility decision
WHERE IT BREAKS
Rules engine version & change-log not public. H.R. 1 work-req logic, SEA 2 exemption rules, SB 1 immigration disclosure rules all being added in 2025–2026.
WHAT WE DON'T KNOW
Rules-engine IV&V process; release cadence; failure mode if rule version mismatches data version.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 9
H.R. 1 work-requirement check (HIP only, quarterly)
OWNER
IEDSS work-req module + 400 new DFR staffers
HANDOFF
Compliance pass / fail / exemption-claimed
WHERE IT BREAKS
80 hours/month threshold + 5 exemption categories (caregiver, pregnancy, SUD, disability, etc.) + 3-month lookback × ~560K HIP enrollees × 4 cycles/year = ~2.24M compliance evaluations/year. SEA 2 1115 amendment still pending CMS approval.
WHAT WE DON'T KNOW
Exemption documentation cadence (how often must caregiver status be re-proven?); CMS approval timing of the 1115 amendment.
PUBLIC COMMENT
H.R. 1 (the 'One Big Beautiful Bill Act,' July 2025) requires verification of work-requirement compliance 'on an ongoing basis and at least quarterly.' Federal implementation deadline January 1, 2027. — CMS · KFF tracker · 2025–2026
OTHER STATES
Arkansas (2018) is the cautionary tale: 18,000 lost coverage in 7 months under work req; 97% of those removed were actually compliant or exempt — they lost coverage because of confusion and reporting failures, not policy non-compliance. Federal court halted the program in April 2019. Georgia Pathways (since July 2023): 4,900 enrolled vs. 240K projected — about 2%; GAO found program spent more on admin than care; Georgia is now moving to verify only at application + annual renewal. — NEJM · Urban Institute · ProPublica · KFF
STEP 10
Notice generated (continued · disenrolled · pending)
OWNER
IEDSS notice generator + DFR
HANDOFF
USPS mail + portal
WHERE IT BREAKS
Notice plain-language compliance and member comprehension are upstream determinants of appeal exercise. Pre-2023 audits flagged notice readability.
WHAT WE DON'T KNOW
Notice receipt rate; comprehension rate; per-program notice variants.
PUBLIC COMMENT
CMS has exercised enforcement discretion to give states until June 3, 2026 to comply with procedural-disenrollment account-transfer and combined-notice requirements; full compliance with all regulations required by December 31, 2026. — CMS · GAO-24-106883 · 2025–2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 11
Disenrollment flows to CoreMMIS member master
OWNER
IEDSS → CoreMMIS interface
HANDOFF
X12 834 to MCEs; eligibility flag in CoreMMIS
WHERE IT BREAKS
Procedural-vs-substantive disenrollment breakdown not publicly published per program. CMS PEAK data captures some of it but with a 6-month lag.
WHAT WE DON'T KNOW
Per-program procedural disenrollment rate (HHW vs HIP vs HCC vs PathWays separately).
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
North Carolina's final procedural disenrollment rate at the end of the unwinding was 12% — only Maine had a lower rate. NC operates an ePASS-driven consolidated workflow + 99% ex parte rate; this combination produced the lowest preventable-loss rate in the country. Indiana's 78% procedural rate sits at the opposite pole. — KFF · NC Health News
STEP 12
Appeal pathway opens (90-day window)
OWNER
FSSA Hearings (ALJ); Aid pending if filed in time
HANDOFF
Internal MCE appeal first for managed care; state fair hearing
WHERE IT BREAKS
Appeal capacity at FSSA Hearings post-unwinding not publicly characterized. ALJ caseload trend not disclosed.
WHAT WE DON'T KNOW
Appeal rate; aid-pending compliance rate; reversal rate at fair hearing.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The 78% procedural disenrollment rate isn't caseworker failure or member negligence — it's the product of a multi-gate workflow where each gate has a small failure probability and the failures compound across millions of events. Adding 400 people to a workflow whose bottleneck is at steps 5–7 (document handling) doesn't solve the bottleneck; it just adds intake capacity around it. EO 25-60's end of self-attestation pushes more events into the manual-proof funnel, where doc-matching is the binding constraint. H.R. 1 and SB 1 layer quarterly cadences onto a system that struggles with annual renewals.

Public signals

  • 78% procedural disenrollment rate during the unwinding (Apr 2023 – Apr 2024) — KFF / CMS PEAK data
  • Pre-PHE Indiana PERM rate: 28.8% (cited in EO 25-60); national PERM RY2025: 6.10%
  • HIP enrollment ~560K; H.R. 1 quarterly verification = ~2.24M compliance events/year
  • 400 new eligibility checkers being hired; 50 onboarded as of late April 2026
  • EO 25-60 (Apr 15, 2025) ends self-attestation; mandates interagency data matching
  • SB 1 (Feb 2026): quarterly checks; immigration disclosure (eff July 2026)

What we don't know yet

  • Indiana's current ex parte success rate (national rate ~41% post-PHE)
  • Per-county DFR queue depth and caseworker-to-population ratios
  • Document rejection breakdown — per-document-type, per-channel
  • Notice comprehension and appeal-exercise rate
  • Per-program procedural disenrollment rate (HHW · HIP · HCC · PathWays)
  • 1115 work-req amendment language and CMS approval timing

What the data reveals

  • Audit the workflow before scaling the hire. The bottleneck is at document-handling, not intake.
  • Document-matching automation (CV/OCR + NLP for document classification) is the highest-ROI intervention. Pre-empts the manual reconciliation queue.
  • Per-county queue visibility is the prerequisite for load rebalancing across the 92 DFR offices.
  • Ex parte success rate transparency would qualify Indiana for CMS technical-assistance funding under the post-unwinding eligibility-modernization initiative.
  • Sequencing matters: H.R. 1 outreach window (Jun 30 – Aug 31, 2026) lands before the SEA 2 1115 amendment is likely approved.
H2HEAT ZONE

The August 2026 master procurement

The August 2026 master procurement combines all four managed care programs (HHW + HIP + HCC + PathWays) into a single bid, target contract start January 1, 2029. Aggregate value ~$68B; ~1.4M Hoosier lives in scope.

STEP 1
Procurement strategy & scope decisions
OWNER
FSSA OMPP + State CIO Lenard + OMB Hershman
HANDOFF
Internal alignment with Governor's Office
WHERE IT BREAKS
Strategy publicly under-disclosed: bundled vs unbundled MCO contracts; carve-in/carve-out decisions; modular vs monolithic MMIS approach.
WHAT WE DON'T KNOW
Whether dental/vision/BH carve-outs are on the table; whether pharmacy carve-out is being reconsidered (CA/NY model).
PUBLIC COMMENT
FSSA Jan 30, 2026 presentation: the procurement combines all four programs at once with aggregate $68B value. The four programs together serve 1.4M people. More information 'won't be available until closer to its release early this fall.' — Indiana Capital Chronicle · Becker's Payer Issues · OPEN MINDS · Feb 4, 2026
OTHER STATES
Pennsylvania (April 2, 2026): Commonwealth Court ORDERED a rebid of all Community HealthChoices managed-LTSS contracts after finding the procurement process was flawed, including bid-scoring issues. This is the most recent procurement-failure cautionary tale and directly relevant to Indiana's evaluation framework. — OPEN MINDS · PA Commonwealth Court
STEP 2
APD/IAPD package prepared for CMS
OWNER
FSSA CIO Arrowood + CMCS DSG (Baltimore)
HANDOFF
Submission to CMS Region 5 with copy to DSG
WHERE IT BREAKS
Mandatory new SMC templates (APD, OAPD, AoA, Intake Form) effective July 1, 2026. Submission after that date must use them.
WHAT WE DON'T KNOW
Whether Indiana's APD is already in template-ready form; CMS pre-approval timing.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Procurement Vehicle (Indiana Department of Administration)
OWNER
IDOA + FSSA
HANDOFF
Vendor competition mechanics; mandatory new SMC procurement standards
WHERE IT BREAKS
Procurement template alignment — Indiana's IDOA forms must absorb CMS's new SMC requirements without losing state-law conformity.
WHAT WE DON'T KNOW
Pre-bid conference scheduling; mandatory vendor briefing requirements.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
RFP issuance (target: August 2026)
OWNER
IDOA + FSSA OMPP
HANDOFF
Posted to Indiana's eProcurement portal; CMS-0057-F compliance language baked in
WHERE IT BREAKS
RFP design window is the lowest-cost intervention point in the entire $68B cycle. Bad requirements compound for 10 years.
WHAT WE DON'T KNOW
Whether MES modular requirements are written tightly enough to drive certification, or loose enough to invite scope creep.
PUBLIC COMMENT
Target RFP issuance: August 2026. Indiana to rebid all four MCO contracts (HHW, HIP, HCC, PathWays) in a single procurement. — Indiana Capital Chronicle · Feb 4, 2026
OTHER STATES
MACPAC: typical state Medicaid managed-care procurement takes 18–24 months. Indiana's ~30-month window (Aug 2026 → Jan 2029) is on the higher end — appropriate given the scale, but the time can erode quickly under protest. Best practice: strengthen evaluation frameworks, clarify scoring criteria, emphasize transparency and defensibility. — MACPAC · SHVS Toolkit
STEP 5
Bidder Q&A and amendments
OWNER
FSSA + IDOA
HANDOFF
Q&A responses posted publicly; amendments shape final bid
WHERE IT BREAKS
Q&A is where the bidder community renegotiates the RFP. Indiana's history is sparse public Q&A; CMS expects deeper engagement.
WHAT WE DON'T KNOW
Pre-bid bidder pool composition; incumbent-vs-challenger ratio.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Proposals received & evaluated
OWNER
FSSA evaluation committee + IDOA observers
HANDOFF
Scoring against published evaluation criteria
WHERE IT BREAKS
Evaluation committee composition; presence of independent technical evaluators; CMS attendance at scoring discussions.
WHAT WE DON'T KNOW
Whether the IBM/ACS lesson is institutionally reflected in the evaluation criteria.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Florida SMMC re-procurement (April 13, 2024): AHCA awarded 6-year contracts to 5 MCOs effective Oct 1, 2024 through Dec 31, 2030 — covering 3.4M enrollees with combined MMA + LTC services. Pennsylvania's Community HealthChoices procurement, by contrast, was ORDERED REBID by the Commonwealth Court on April 2, 2026 due to bid-scoring flaws. The contrast is in evaluation defensibility. — FL AHCA · OPEN MINDS · PA Commonwealth Court
STEP 7
Bidder selection & CMS pre-approval review
OWNER
FSSA + CMS Region 5 + CMCS DSG
HANDOFF
CMS reviews selection memo, contract draft, IAPD update
WHERE IT BREAKS
CMS approval is a critical-path dependency. Region 5 → DSG → OCIIO routing.
WHAT WE DON'T KNOW
CMS internal SLA for review of a $68B selection.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
Contract negotiation & execution
OWNER
FSSA OMPP + selected MCEs + General Counsel Stover
HANDOFF
Signed contracts with SMC template adherence + CMS-0057-F binding language
WHERE IT BREAKS
Contract clauses on encounter data quality, SMC certification timing, sub-capitation visibility, audit cooperation, and termination triggers.
WHAT WE DON'T KNOW
Whether encounter data quality is contractually tied to capitation withholds.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 9
Transition planning (~24 months)
OWNER
FSSA OMPP + new MCEs + Gainwell + Deloitte + Maximus
HANDOFF
Run-out plans for outgoing arrangements; cutover plans for new
WHERE IT BREAKS
Transition is where IBM/ACS-class failures originate. Data migration, member re-assignment, provider re-contracting, MMIS interfaces, encounter pipelines.
WHAT WE DON'T KNOW
IV&V structure; readiness review milestones; CMS go/no-go gates.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Iowa IA Health Link (2016): RFP-to-launch compressed to <12 months; CMS twice postponed the launch for 'inadequate provider networks and communication.' AmeriHealth Caritas exited mid-cycle in 2017. Branstad's $232M savings projection actualized at ~$47M (20% of target). Illinois HealthChoice (Jan 2018): baked 90-day member transition + 180-day out-of-network provider transition into the template — Indiana's MDwise honor window matches this national norm. — IA HHS · IL HFS · Health Management
STEP 10
Contract start date (January 1, 2029)
OWNER
FSSA + new MCEs
HANDOFF
Live operations; CMS go-live reporting
WHERE IT BREAKS
Day-one operational risk: member auto-assignment notices, provider network adequacy, claims pipeline, encounter pipeline. Indiana's largest single transition.
WHAT WE DON'T KNOW
Whether parallel operations / staged cutover is planned.
PUBLIC COMMENT
Roob: target for new contracts to be effective January 1, 2029. — Indiana Capital Chronicle · Feb 4, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 11
First-year SMC certification cycle
OWNER
FSSA CIO + vendor + CMS
HANDOFF
Module certification submissions to CMS SMC repository
WHERE IT BREAKS
Modules certified BEFORE contract start earn 75% M&O match from day one. Modules certified after cost the state the difference until certified.
WHAT WE DON'T KNOW
Indiana's module certification roadmap; which modules will be ready by 1/1/2029.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

Procurements at this scale fail in the requirements phase, not the build phase. The IBM/ACS contract failed because the requirements didn't specify what was actually needed; the corrective lessons were drawn in 2009 and have not yet been re-tested at this scale. Two windows determine the next decade: the RFP design (now through August 2026), and the transition (Jan 2027 through Dec 2028). Both are short. The CMS-0057-F deadlines (PA decision timeframes Jan 2026, full FHIR API Jan 2027) and SMC template mandate (July 2026) all pre-date contract start, so they must be designed into the RFP rather than negotiated in.

Public signals

  • RFP target: August 2026 (Indiana Capital Chronicle, Feb 4, 2026)
  • Contract start: January 1, 2029 — ~30-month transition window
  • Total value: ~$68B across the contract life
  • Four programs (HHW + HIP + HCC + PathWays) combined into a single bid cycle
  • Mandatory new SMC templates: July 1, 2026
  • Zero confirmed Indiana MES modules on CMS public SMC repository
  • CMS-0057-F: PA decision timeframes Jan 1, 2026; full FHIR PA API Jan 1, 2027

What we don't know yet

  • RFP scope details: carve-in/carve-out, module boundaries, modular MMIS approach
  • Evaluation committee composition and independent technical evaluators
  • CMS internal SLA for selection review
  • Transition IV&V structure and CMS go/no-go gates
  • Encounter data quality contractual mechanics

What the data reveals

  • The 90 days before RFP issuance are the highest-leverage window in the entire cycle. Requirements written now determine the next 10 years.
  • SMC template readiness is a precondition. Indiana needs to be drafting against the new templates today, not in July.
  • A pre-bid technical advisory function (independent of incumbents) reduces the IBM/ACS failure mode.
  • Encounter data quality clauses with capitation withholds are the single highest-impact contract change.
  • Transition IV&V should be CMS-co-funded under MES enhanced match; bake it into the APD.
H3HEAT ZONE

Hospital reform + State Directed Payment

Indiana's first post-PHE hospital rate restructuring. $1.866B SDP, tiered ACR (158% rural / 125% high-commercial / 100% physician). CMS approved Apr 28 + May 1, 2026.

STEP 1
Hospital Assessment Fee design & legislative approval
OWNER
Indiana General Assembly + IHA + FSSA
HANDOFF
HAF rate set; legislative authority granted
WHERE IT BREAKS
HAF must satisfy 42 CFR §433.68 broad-based / uniform / hold-harmless tests. Hold-harmless test is the most-litigated.
WHAT WE DON'T KNOW
Per-hospital HAF impact; net financial position by hospital class.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
47 states had hospital provider taxes in FY 2025 (KFF) — Indiana joins 22 states adding MCO taxes in FY 2026 (Nebraska also added in FY26). H.R. 1 'significantly limits states' ability to impose or raise taxes on health care providers' going forward — meaning Indiana's hospital-tax architecture (now at the 6% federal limit) sits in the shadow of new federal restrictions. Provider tax revenue averages 18% of non-federal share of Medicaid nationally. — KFF FY 2025 Medicaid Budget Survey · Bipartisan Policy Center · Commonwealth Fund
STEP 2
Preprint submission to CMS
OWNER
FSSA OMPP + CMS Region 5
HANDOFF
Preprint reviewed by Region 5 + CMCS DSG
WHERE IT BREAKS
Preprint is the CMS document where SDP mechanics are vetted. ACR tier design must align with 2024 Access Rule demonstration requirements.
WHAT WE DON'T KNOW
Public preprint redactions; CMS comments resolution log.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
CMS approval — HAF (Apr 28, 2026) + SDP (May 1, 2026)
OWNER
CMS CMCS
HANDOFF
Approval letters issued, retroactive provisions specified
WHERE IT BREAKS
HAF approved retroactive to July 1, 2025 — meaning rate-true-up cycle through MCEs takes additional time post-approval.
WHAT WE DON'T KNOW
Approval letter conditions; MOEs (maintenance-of-effort) provisions.
PUBLIC COMMENT
CMS approved the revised Hospital Assessment Fee on April 28, 2026 (retroactive to July 1, 2025); the new State Directed Payment program approved May 1, 2026. — Indiana Capital Chronicle · IHA · Apr 28 / May 1, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Capitation rate adjustment to MCEs
OWNER
FSSA OMPP rate-setting + Milliman (actuary)
HANDOFF
MCE capitation rates re-cert with the new SDP folded in
WHERE IT BREAKS
SDP is paid through MCEs as a directed payment requirement — meaning capitation rates increase commensurately and MCE pass-through to hospitals is monitored.
WHAT WE DON'T KNOW
Actuarial certification language; pass-through audit cadence.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Texas has used SDPs heavily — pioneered ACR-based payment structures. Maryland operates an all-payer hospital rate-setting model (unique in the country). North Carolina integrates HealthyNC SDP with social-determinants metrics. Indiana's tiered ACR (158%/125%/100%) is a TX-style mechanism with NC-style equity tiering. — MACPAC · KFF
STEP 5
Tiered ACR ceiling enforcement (158% / 125% / 100%)
OWNER
MCEs (operationally) + FSSA OMPP (policy)
HANDOFF
Hospital contracts re-negotiated within ACR tier caps
WHERE IT BREAKS
Tiered ACR concentrates payment increases on rural and CAH facilities; caps consolidated, high-commercial-price systems. Operationally, MCEs must re-paper hospital contracts.
WHAT WE DON'T KNOW
Per-hospital ACR positioning; consolidation/divestiture response from high-commercial systems.
PUBLIC COMMENT
Roob: 'This is the first time Medicaid has ever been used like this... a new covenant.' Tiered ACR directs more money toward lower-cost and rural providers; creates financial pressure on higher-priced consolidated systems. — Indiana Capital Chronicle · WBIW · May 15, 2026
OTHER STATES
Maryland operates the only all-payer hospital rate regulation system in the country since 1971 — every payer (Medicare, Medicaid, commercial, self-insured) pays the same rate for the same service at a given hospital. HSCRC sets rates under a 1814(b) SSA Medicare waiver. Since Nov 1, 2024 MD operates under the AHEAD Model (successor to Total Cost of Care). Texas pioneered ACR-based SDPs. Indiana's tiered ACR (158%/125%/100%) blends a TX-style payment mechanism with equity tiering. — CMS · MD HSCRC · Maryland Hospital Association · Healthcare Value Hub
STEP 6
Quarterly directed-payment reconciliation
OWNER
FSSA + MCEs + Gainwell (claims) + IHA
HANDOFF
Pass-through report to CMS; over/under reconciliation
WHERE IT BREAKS
Reconciliation requires clean encounter data — the same data quality issue that breaks rate setting elsewhere.
WHAT WE DON'T KNOW
Reconciliation cycle time; encounter-error reject rate from MCEs to CoreMMIS.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
H.R. 1 SDP restrictions take effect (federal layer)
OWNER
Congress + CMS
HANDOFF
Federal restrictions narrow SDP eligibility post-Oct 2025
WHERE IT BREAKS
Indiana's SDP design is now bracketed by H.R. 1's further SDP restrictions on directed-payment scope and amount.
WHAT WE DON'T KNOW
How H.R. 1 implementation rules will interpret tiered-ACR mechanisms.
PUBLIC COMMENT
Payment changes take effect January 1, 2026. HAF formula shifted from hospital patient days to total net patient revenue, maximizing the tax up to the 6% federal limit; county hospitals exempt via intergovernmental transfers. — Indiana Capital Chronicle · May 15, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The May 2026 hospital package is the most significant Medicaid rate restructuring Indiana has executed since the post-PHE unwinding. It threads three needles simultaneously: (1) shore up rural/CAH viability; (2) cap consolidated systems' Medicaid pricing power; (3) hold physicians at 100% of Medicare to protect access. The fiscal architecture works only if MCE pass-through is verifiable and encounter data clean. The H.R. 1 layer adds federal uncertainty: future SDP designs may be constrained.

Public signals

  • $1.866B distributable through SDP for 2026
  • Tiered ACR: 158% rural/CAH · 125% high-commercial · 100% physician of 2025 Medicare
  • HAF approved Apr 28, 2026 (retroactive to July 1, 2025)
  • SDP approved May 1, 2026
  • Source: FSSA hospital reform package release; Indiana Capital Chronicle (May 15, 2026)

What we don't know yet

  • Per-hospital ACR positioning
  • MCE pass-through audit cadence
  • Encounter-error reject rate (the operational binding constraint)
  • Consolidation/divestiture response from high-commercial systems
  • How H.R. 1 implementation rules will interpret tiered-ACR mechanisms

What the data reveals

  • Encounter data quality (already an exposure under H5/PathWays) is now also the binding constraint on hospital reform reconciliation.
  • MCE pass-through auditing is a new operational workstream — needs technical infrastructure inside FSSA.
  • Hospital network-adequacy monitoring should be paired with the rate restructuring; rural-CAH facilities need access tracking.
  • H.R. 1 SDP rules will determine whether the current structure survives intact past 2027 — design contingency now.
H4HEAT ZONE

Provider integrity audits

Two active audit surfaces. ABA: $56M confirmed + $76.7M potentially improper (HHS OIG 2024). Attendant care: $200M sought from 5 largest providers (FSSA April 2026). Documentation gaps + EVV non-compliance the common surface.

STEP 1
Pattern detection / audit trigger
OWNER
FSSA OMPP Office of Program Integrity + HHS OIG + CMS UPICs
HANDOFF
Open audit case file
WHERE IT BREAKS
Pattern detection methods not publicly characterized (rules-based vs ML); referral mechanics between FSSA OPI, MFCU, and OIG opaque.
WHAT WE DON'T KNOW
False positive rate on triggers; coordination of overlapping audits across agencies.
PUBLIC COMMENT
WISH-TV framed the Braun administration push as 'the free lunch is over' — broader effort to curtail Medicaid waste, fraud, and abuse including the attendant-care audit, ABA reforms, and the 340B change. — WISH-TV · Mar 2026
OTHER STATES
New York operates the Office of Medicaid Inspector General (OMIG) as a SEPARATE Inspector General office — distinct from the state Medicaid agency. OMIG conducted 266 pre-payment reviews in 2022, with sophisticated ML-driven pattern recognition and outlier analysis baked into the 2026 work plan. Indiana's FSSA OPI sits inside the program agency; the structural separation matters for independence and pre-payment capability. — NY OMIG · OMIG 2022 Annual Report · OMIG 2026 Work Plan
STEP 2
Records request to provider
OWNER
Audit agency (OPI / OIG / UPIC / MFCU)
HANDOFF
Provider produces records within statutory window
WHERE IT BREAKS
Document retention varies by provider class; small/medium providers often lack structured retention systems.
WHAT WE DON'T KNOW
Records-production timeline median; refusal rate; partial-records rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Medical record / EVV review
OWNER
Audit team (often outsourced to clinical reviewers)
HANDOFF
Findings documented at service-line and beneficiary level
WHERE IT BREAKS
Documentation gaps + EVV non-compliance are the common audit findings. ABA service notes often lack treatment-plan tie. Attendant care EVV records often lack co-located service location.
WHAT WE DON'T KNOW
Per-service-line documentation defect rate; EVV-claim match rate.
PUBLIC COMMENT
FSSA audit reviewed claims 1/1/2022 – 3/31/2025 from Indiana's five largest attendant-care providers (Guardian Care, Healing Hands Personal Services, Help at Home, Tendercare Home Health, Team Select Home Care). Statistically valid random sampling of 625 claim lines. 'Nearly all reviewed claims had multiple issues, including missing criminal background checks, noncovered clinical tasks, insufficient documentation, misaligned authorizations, and other significant regulatory noncompliance.' Triggered by a $150M claim surge 2021 → 2022. — Indiana Capital Chronicle · WFYI · Fox 59 · WBIW · Apr 23–24, 2026
OTHER STATES
OIG audits typically cover 2-year review periods; Indiana's FSSA attendant-care audit covers 1/1/2022–3/31/2025 (a longer 3-year window). NY OMIG conducts 266+ pre-payment reviews annually per its 2022 Annual Report — pre-payment posture catches issues earlier than the retrospective audits dominant in Indiana. — HHS OIG · NY OMIG 2022 Annual Report
STEP 4
Statistical extrapolation
OWNER
Audit statistician (HHS OIG uses RAT-STATS; UPICs vary)
HANDOFF
Extrapolated overpayment amount derived from sample
WHERE IT BREAKS
Extrapolation methodology is the most-litigated step. ABA audit's $56M-confirmed/$78M-potentially-improper split is the extrapolation tail.
WHAT WE DON'T KNOW
Sample-size adequacy challenges; extrapolation methodology in attendant care audit.
PUBLIC COMMENT
HHS OIG (Dec 2024) found Indiana made at least $56M in improper FFS Medicaid payments for ABA between January 2019 and December 2020, plus an additional $76.7M potentially improper. Findings: documentation, diagnostic evaluations, staff credentials, referrals. — HHS OIG · Dec 2024
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Findings letter / notice of overpayment
OWNER
Audit agency
HANDOFF
Provider response window opens (typically 60 days)
WHERE IT BREAKS
Findings letters trigger appeal rights; specifics of appeal path vary by audit type (OIG → HHS DAB; UPIC → MAC reconsideration; state → FSSA Hearings).
WHAT WE DON'T KNOW
Per-audit-type appeal exhaustion rate; reversal rate at first appeal.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Provider appeal & rebuttal
OWNER
Provider + counsel; for state findings: FSSA Hearings ALJ
HANDOFF
Reconsideration / hearing decision
WHERE IT BREAKS
Audit findings often survive provider contest because documentation gaps are evidentiary; less than 30% reversal nationally.
WHAT WE DON'T KNOW
Indiana-specific reversal rate; per-service-line reversal rate.
PUBLIC COMMENT
Tendercare Home Health CEO Eric Deitchman publicly: 'I'm surprised we got listed publicly while we are working on our appeal. They said our care plans weren't up to par.' — Indiana Capital Chronicle · Apr 24, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Recoupment / settlement
OWNER
FSSA OMPP / MFCU / CMS
HANDOFF
Funds returned to state; federal share returned to CMS
WHERE IT BREAKS
Settlement vs litigation choice; settlement amount discount typically 20–40%.
WHAT WE DON'T KNOW
Indiana settlement-vs-litigation policy; per-provider settlement amounts.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
Referral to MFCU if fraud suspected
OWNER
FSSA OPI → AG MFCU (Whitmire)
HANDOFF
Criminal investigation; exclusion proceedings
WHERE IT BREAKS
Referral mechanics: when does FSSA refer vs handle internally? MFCU declination criteria not public.
WHAT WE DON'T KNOW
Referral volume; declination rate; exclusion outcomes.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 9
Governor's Working Group / legislative response
OWNER
Governor's Office + General Assembly
HANDOFF
Policy change (e.g., ABA usage cap; rate change)
WHERE IT BREAKS
Working Group recommendations (Nov 2025) on ABA usage cap and rate changes — translation into administrative or legislative action.
WHAT WE DON'T KNOW
Implementation status of Working Group recommendations.
PUBLIC COMMENT
Governor's Medicaid Working Group (Nov 2025) recommended an ABA usage cap and rate changes. April 1, 2026 reforms went live: 4,000-hour lifetime cap with 15 hrs/week medical-necessity exception; 6% rate cut on max fee rates (except group); age-cap at 21 (EPSDT only); CASP accreditation required Oct 1, 2027. — Indiana Capital Chronicle · Hall Render · Behavioral Health Business · Nov 2025 – Apr 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 10
Systemic data / analytics build-out
OWNER
FSSA OPI + future MFADS / pattern-detection capacity
HANDOFF
Pattern detection improves; subsequent triggers fire faster
WHERE IT BREAKS
Indiana's current pattern-detection capability is largely retrospective and rules-based. ML/anomaly approaches would catch second-order patterns earlier.
WHAT WE DON'T KNOW
Current MFADS capability map; ML/AI usage in pattern detection.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
NY OMIG's self-disclosure program lets providers proactively report and return overpayments within 60 days of identification, reducing the audit-recoup posture. Oklahoma has piloted FHIR-based pre-payment claim integrity. The shift is from retrospective recoup to prospective prevention. — NY OMIG · Oklahoma HCA

Diagnosis

Two audits at $56M and $200M, in different service lines, with the same root surface (documentation + EVV), is a pattern. The pattern indicates that Indiana's claims-and-encounter data already contains the signal needed to predict the next audit — but the detection layer is downstream of the spending event. The integrity exposure is concentrated in a small number of large providers in a small number of service lines. Pre-payment integrity (claim edit + EVV validation at submit) catches earlier and cheaper than post-payment audit. The Working Group's ABA cap recommendation is a policy response; the operational response is a detection-and-prevention upgrade.

Public signals

  • ABA audit (HHS OIG, 2024): $56M confirmed improper, $76.7M potentially improper
  • FSSA attendant care audit (April 2026): $200M sought from 5 largest providers
  • Trigger for attendant care audit: $150M claim surge 2021 → 2022
  • Governor's Medicaid Working Group (Nov 2025) recommended ABA usage cap + rate changes
  • EVV state aggregator: Sandata (open-vendor model)
  • MFCU Director: Matthew Whitmire (AG Rokita)

What we don't know yet

  • FSSA OPI ↔ MFCU ↔ OIG referral mechanics
  • ML/AI use in current pattern detection
  • Per-service-line documentation defect rate (baseline)
  • EVV-claim match rate in attendant care
  • Implementation status of Working Group recommendations
  • Indiana settlement-vs-litigation policy

What the data reveals

  • Pre-payment integrity (claim edit + EVV validation at submit) is the single highest-ROI capability gap — catches at submission, not 18 months post-payment.
  • An audit-defensible pattern engine in attendant care and ABA would convert the current reactive audit posture into a continuous-monitoring posture.
  • EVV reconciliation should be real-time, not batch — current batch architecture is the proximate cause of the audit signal latency.
  • Working Group implementation should be tracked operationally, not just legislatively. Rate changes that don't account for documentation requirements simply shift the surface.
H5HEAT ZONE

PathWays operational quality

Indiana's first managed-LTSS program, in year 2. 11,296 waiver waitlist (714 invitations Feb 2026). $462M delayed NF payments (Feb–Apr 2026). HEA 1277 carves long-stay back to FFS, eff July 1, 2027.

STEP 1
Member identification & intake
OWNER
DDARS (Mitchell) + Area Agencies on Aging (AAAs)
HANDOFF
Intake screening → Level of Care determination
WHERE IT BREAKS
Intake throughput is the upstream bottleneck. 11,296 waitlist with 714 invitations in Feb 2026 reflects intake capacity, not slot capacity.
WHAT WE DON'T KNOW
AAA-by-AAA intake throughput; per-region waitlist depth.
PUBLIC COMMENT
11,296 waiver waitlist with only 714 invitations issued in February 2026. The Arc of Indiana publicly tracks; ACLU of Indiana filed an HCBS waitlist class action in S.D. Indiana (2024, ADA/Olmstead). — The Arc of Indiana · ACLU of Indiana · 2024–2026
OTHER STATES
Arizona ALTCS (since 1989) is the oldest managed-LTSS program in the country and the operational maturity benchmark. Tennessee CHOICES and Kansas KanCare have similar contractor mixes to Indiana. Pennsylvania Community HealthChoices launched in 2018 and is the closest structural analogue — currently under court-ordered rebid (see H2.1). — OPEN MINDS · CHCS · MACPAC
STEP 2
Functional eligibility / Level of Care
OWNER
DDARS assessor; standardized assessment tool
HANDOFF
Eligibility decision → service plan
WHERE IT BREAKS
Assessment tool reliability across assessors; inter-rater agreement not publicly characterized.
WHAT WE DON'T KNOW
Inter-rater reliability; reassessment cadence.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Arizona ALTCS uses a single state-administered functional + financial eligibility assessment; Texas STAR+PLUS combines functional + intake in one bundled assessment. Indiana's separation between DDARS functional assessment and DFR financial assessment is the national majority pattern but creates handoff friction. — AZ AHCCCS · TX HHSC
STEP 3
Plan auto-assignment or selection (Anthem · Humana · UHC)
OWNER
Maximus (enrollment broker)
HANDOFF
Member assigned to one of three PathWays MCEs
WHERE IT BREAKS
Member education on plan choice; per-MCE network depth varies by region.
WHAT WE DON'T KNOW
Per-MCE assignment distribution; member plan-switch rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Care planning by MCE
OWNER
PathWays MCE care manager
HANDOFF
Plan of care issued; services authorized
WHERE IT BREAKS
Care plan quality and timeliness; care manager caseload sizes not public.
WHAT WE DON'T KNOW
Per-MCE care manager caseload; care plan turnaround time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
PA OLTL (Office of Long-Term Living) sits inside DHS and administers care planning separately from the MCEs — a different governance pattern from Indiana's DDARS + MCE shared model. PA reports care manager caseload metrics publicly. — PA DHS · OLTL
STEP 5
Service delivery (HCBS · attendant care · NF)
OWNER
Provider (independent or agency)
HANDOFF
Service rendered; encounter built
WHERE IT BREAKS
Attendant care providers are exactly the surface H4 (provider integrity) is concentrated on. Documentation + EVV.
WHAT WE DON'T KNOW
Per-service-line encounter quality; provider EVV compliance rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
EVV capture (Sandata or open-vendor)
OWNER
Provider EVV system → Sandata aggregator
HANDOFF
EVV record posted to Sandata; matches against claim
WHERE IT BREAKS
EVV capture is real-time; reconciliation to claim is batch (typically nightly). Latency creates the gap audits exploit.
WHAT WE DON'T KNOW
EVV-to-claim match rate; alternate-vendor (HHAeXchange et al.) data quality.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Claim submission
OWNER
Provider / clearinghouse
HANDOFF
MCE adjudication (PathWays) or CoreMMIS (FFS waivers)
WHERE IT BREAKS
Sub-capitation by MCEs to delegated providers loses encounter visibility — a national pattern that applies in Indiana but is not publicly characterized.
WHAT WE DON'T KNOW
Sub-capitation arrangements and their encounter-quality impact.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
NF payment cycle (quarterly, CMS-method)
OWNER
FSSA OMPP + PathWays MCEs
HANDOFF
Quarterly payment from MCE to NF
WHERE IT BREAKS
$462M in delayed NF payments (Feb–Apr 2026) reflects cycle time between state, CMS, and MCE on still-new contract structure.
WHAT WE DON'T KNOW
Per-NF payment-delay distribution; cause split (MCE-side vs CMS-method vs state).
PUBLIC COMMENT
$462M in NF payments delayed across 496 nursing homes; December and March payments missed heading into June. CMS hasn't approved Indiana's FY2026 methodology — state submitted June 2025, CMS still requesting data 9+ months later. H.R. 1 'added some wrinkles' to the calculation. Roob: 'I never would have pursued this program... it doesn't make sense for the population it serves.' — Indiana Capital Chronicle · WFYI · Skilled Nursing News · Apr 8, 2026 + Jun 10, 2025 testimony
OTHER STATES
Pennsylvania's mature CHC program (8 years in operation) does not have $462M-class quarterly NF payment delays — the methodology is well-established. The delays Indiana is experiencing are characteristic of a year-1–2 managed-LTSS program; PA's earlier years had analogous friction. The cycle time normalizes if the underlying methodology survives the H.R. 1 disruption. — PA DHS · OPEN MINDS
STEP 9
Encounter data submission MCE → CoreMMIS
OWNER
PathWays MCEs
HANDOFF
Encounter file ingestion to CoreMMIS analytics
WHERE IT BREAKS
Year 1–2 encounter data is structurally weak by national pattern. PathWays encounter quality publicly unaffirmed.
WHAT WE DON'T KNOW
Encounter file reject rate; resubmission cycle time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 10
Rate setting for next cycle
OWNER
FSSA + Milliman (actuary)
HANDOFF
Capitation rates re-cert against encounter data
WHERE IT BREAKS
If encounter quality is weak, rate setting is on shaky ground. The forecasting reform was triggered by exactly this risk.
WHAT WE DON'T KNOW
Actuarial confidence interval on PathWays rates.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 11
HEA 1277 long-stay carve-out (effective July 1, 2027)
OWNER
FSSA + General Assembly
HANDOFF
Long-stay (>100 days) NF residents return to FFS
WHERE IT BREAKS
Carve-out is a legislative reaction to MCE-NF payment friction; operational implementation requires re-papering hospital and NF contracts on FFS basis.
WHAT WE DON'T KNOW
Carve-out implementation plan; member transition mechanics.
PUBLIC COMMENT
HEA 1277 (authored by Rep. Brad Barrett, R-Richmond; sponsored by Sen. Mike Crider, R-Greenfield) signed by Gov. Braun March 12, 2026 — carves long-stay (>100 days) NF residents out of PathWays back to FFS effective July 1, 2027. Also imposes individual PathWays-waiver cost limit and requires FSSA to file a standalone assisted-living waiver application with CMS by September 1, 2026. — Indiana HCA · OPEN MINDS · Purdue Exponent · Mar 12, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

PathWays' operational health concentrates on two seams: the intake throughput (waitlist) and the encounter-to-rate-setting loop. The $462M NF payment delay is a symptom; the underlying issue is cycle time between state, CMS, and MCE on a still-new contract structure. The HEA 1277 long-stay carve-out is a legislative reaction that doesn't fix the underlying mechanism — it just removes the most expensive population from the structure that's having trouble. Encounter data quality in years 1–2 is the single most important operational metric for the next rate-setting cycle.

Public signals

  • 11,296 waiver waitlist (Feb 2026)
  • 714 invitations issued in Feb 2026
  • $462M delayed NF payments (Feb–Apr 2026)
  • PathWays launched July 1, 2024; ~120K lives at launch
  • MCEs: Anthem · Humana · UnitedHealthcare
  • HEA 1277 signed March 12, 2026; long-stay carve-out effective July 1, 2027

What we don't know yet

  • Per-MCE encounter-file reject rate
  • Sub-capitation arrangements and encounter-quality impact
  • AAA-by-AAA intake throughput
  • Per-NF payment-delay distribution
  • EVV-to-claim match rate in attendant care
  • Actuarial confidence interval on PathWays rates

What the data reveals

  • Encounter data quality sprint in years 1–2 is the single highest-leverage operational intervention. Without it, the next rate cycle and HEA 1277 transition are both compromised.
  • Intake throughput diagnosis (per-AAA) is a prerequisite to reducing the waitlist — adding slots won't help if intake is the bottleneck.
  • NF payment-cycle diagnosis: is the latency MCE-side, CMS-method, or state-side? Different fixes.
  • HEA 1277 transition planning should begin now, 14 months before effective date — long-stay populations need stable care continuity.
H6HEAT ZONE

H.R. 1 work-requirement rollout

Quarterly verification + 3-month lookback for ~560K HIP enrollees. Outreach window Jun 30 – Aug 31, 2026. 400 staffers (50 onboarded late April 2026). Implementation deadline Jan 1, 2027.

STEP 1
Federal rule clarification & state election
OWNER
Congress · CMS · FSSA OMPP
HANDOFF
Indiana elected quarterly + 3-month lookback (among most demanding)
WHERE IT BREAKS
Election locked in; federal rule details still emerging.
WHAT WE DON'T KNOW
CMS clarifying guidance timing for implementation details.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
SEA 2 1115 amendment package
OWNER
FSSA OMPP + CMS Region 5
HANDOFF
1115 amendment under CMS review
WHERE IT BREAKS
Approval timing controls go-live. Past 1115 work-req approvals (Kentucky, Arkansas) faced litigation.
WHAT WE DON'T KNOW
CMS approval timing; conditions of approval.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
H.R. 1 (Big Beautiful Bill, July 2025) closed the 1115 waiver path for work requirements — federal framework supersedes. Arkansas re-filed a work-req waiver in January 2025 anyway; Stewart v. Azar (KY HEALTH) and Gresham v. Azar (AR) set the prior CMS-approval litigation risk pattern. — Arkansas Advocate · KFF · CMS
STEP 3
Workflow design (IEDSS + DFR)
OWNER
FSSA CIO Arrowood + DFR Beam
HANDOFF
Rules engine update + caseworker process
WHERE IT BREAKS
80-hour/month threshold + 5 exemption categories + 3-month lookback × quarterly cadence = high-complexity rule set.
WHAT WE DON'T KNOW
Rules engine release timeline; IV&V scope.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Hiring 400 eligibility checkers
OWNER
FSSA HR + DFR
HANDOFF
Onboarding · training · production
WHERE IT BREAKS
50 onboarded by late April 2026; 350 more to onboard within ~10 weeks of outreach window opening.
WHAT WE DON'T KNOW
Training curriculum completeness; per-cohort time-to-production.
PUBLIC COMMENT
FSSA hiring 400 employees to verify eligibility; 50 onboarded as of late April 2026. Effort began the prior month. — Indiana Capital Chronicle · Apr 29, 2026
OTHER STATES
Georgia Pathways spent more on administration than on health care, per a GAO report. Arkansas 2018 hired far fewer eligibility workers but produced 18,000 disenrollments in 7 months — the worker count isn't the binding constraint, the workflow design is. Indiana adding 400 staffers without restructuring the workflow risks the same outcome. — GAO · ProPublica · NEJM
STEP 5
Member outreach window Jun 30 – Aug 31, 2026
OWNER
FSSA + MCEs + advocacy partners
HANDOFF
Outbound mail + portal notification + MCE member services
WHERE IT BREAKS
Outreach is single-shot at members already in the renewal funnel. Outreach quality + comprehension drives the per-member compliance result.
WHAT WE DON'T KNOW
Outreach plain-language compliance; comprehension testing.
PUBLIC COMMENT
Mandatory member outreach window June 30 – August 31, 2026. Federal implementation deadline January 1, 2027 with possible extensions through Dec 31, 2028. — FSSA · KFF tracker · 2026
OTHER STATES
Arkansas 2018: outreach campaign was insufficient — confusion + lack of awareness drove the 18,000-person coverage loss in 7 months. 97% of those who lost coverage were actually compliant or exempt. The takeaway for Indiana's outreach window: a single-shot mail campaign in summer 2026 reproduces the failure mode. — NEJM · Commonwealth Fund · Urban Institute
STEP 6
Member documents work activity OR claims exemption
OWNER
Member; navigators; employer for verification
HANDOFF
Documentation uploaded via fssabenefits.in.gov or DFR channel
WHERE IT BREAKS
This is where the same workflow that produced 78% procedural disenrollment now carries quarterly verification.
WHAT WE DON'T KNOW
Documentation rate by activity type (wages vs school vs caregiver vs SUD).
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Quarterly compliance evaluation
OWNER
IEDSS work-req module + 400 DFR staffers
HANDOFF
Compliance result → continued / non-compliant / exempt
WHERE IT BREAKS
Volume math: ~560K HIP × 4 cycles = 2.24M evaluations/year, on top of annual renewals (~560K) and ex parte attempts (~560K).
WHAT WE DON'T KNOW
Evaluation throughput per staffer; auto-evaluation share.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Georgia Pathways is the only currently-operating state work-requirement program. Compliance verification is monthly via online portal — and the program is shifting to verification at application + annual renewal (de facto admitting the ongoing-reporting model doesn't work). 4,900 enrolled vs. 240K projected = 2% — a strong negative indicator for the policy theory itself. — GA DCH · WABE · ProPublica · GAO
STEP 8
Notice of non-compliance
OWNER
IEDSS notice generator + DFR
HANDOFF
USPS + portal; cure period before disenrollment
WHERE IT BREAKS
Notice clarity + cure-period mechanics drive the per-member disenrollment outcome.
WHAT WE DON'T KNOW
Cure period rules; per-MCE outreach coordination during cure.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Arkansas: of 18,000 people who lost coverage, 97% were compliant or exempt — the system removed them anyway because the reporting failure was procedural. Indiana's 78% procedural disenrollment rate during the unwinding is the same pattern. Notice clarity + cure-period mechanics determine whether the policy outcome matches the policy intent. — NEJM · Urban Institute
STEP 9
Disenrollment for non-compliance
OWNER
IEDSS → CoreMMIS member master
HANDOFF
X12 834 to MCE
WHERE IT BREAKS
Procedural-vs-substantive non-compliance breakdown is the critical metric — procedural failures aren't policy success.
WHAT WE DON'T KNOW
Per-cycle procedural-vs-substantive split.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 10
Appeal pathway
OWNER
FSSA Hearings ALJ + MCE internal
HANDOFF
Internal MCE appeal → state fair hearing
WHERE IT BREAKS
Appeal capacity at scale; aid-pending mechanics.
WHAT WE DON'T KNOW
Appeal volume forecast vs ALJ capacity.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

H.R. 1 quarterly verification on top of an unchanged renewal workflow produces the same operational risk that drove the 78% procedural disenrollment rate during the unwinding — at four times the cadence. The 400 staffers are needed, but they don't change the workflow's structural failure modes (document handling, notice comprehension, channel mismatch). Indiana elected the most demanding implementation parameters in the country (quarterly + 3-month lookback); the implementation will reveal whether that election is operationally sustainable. The Kentucky / Arkansas litigation history means CMS approval timing and conditions of approval are non-trivial path dependencies.

Public signals

  • Indiana elected quarterly verification + 3-month lookback (most demanding in the country)
  • ~560K HIP enrollees → ~2.24M compliance events/year
  • 400 staffers being hired; 50 onboarded late April 2026
  • Outreach window: June 30 – August 31, 2026
  • Federal implementation deadline: January 1, 2027 (possible extensions through Dec 31, 2028)
  • SEA 2 (2025) authorizes; 1115 amendment pending

What we don't know yet

  • CMS 1115 amendment approval timing
  • Rules engine release date for work-req module
  • Per-staffer evaluation throughput
  • Auto-evaluation share (how much can be automated vs human)
  • Procedural-vs-substantive non-compliance split (the key metric)
  • Appeal volume forecast vs ALJ capacity

What the data reveals

  • Workflow audit BEFORE Jan 1, 2027 — same intervention as H1, even higher urgency.
  • Auto-evaluation share is the operational lever. If 70%+ of compliance events can be auto-resolved against existing data, throughput math works. If <40%, it doesn't.
  • Outreach comprehension testing in May 2026 (before the window) is the lowest-cost mitigation.
  • Exemption documentation persistence — caregiver / disability / pregnancy status must not require re-proof every quarter or compliance math breaks.
  • Procedural-vs-substantive transparency: publish the split. Without it, success can't be distinguished from operational failure.
H7HEAT ZONE

Forecasting reform

The political wound from 2023. $984M underestimated across FY24–25. Drove Steinmetz resignation (Dec 2024), Rusyniak departure (Jan 2025), and Mishler's Medicaid Oversight Committee.

STEP 1
Forecast methodology design
OWNER
FSSA OMPP + Office of Management & Budget + actuary
HANDOFF
December forecast feeds biennial budget cycle
WHERE IT BREAKS
Pre-2023 methodology relied on pre-pandemic utilization rates that didn't reflect post-PHE actual experience.
WHAT WE DON'T KNOW
Current methodology revisions; assumption-testing cadence.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Washington's MAEFW (Medical Assistance Expenditure Forecast Workgroup) reviews financial data, caseloads, FMAP, and step adjustments in a documented workgroup process — twice yearly (Feb + Oct). The methodology is published. Indiana's revised forecast methodology post-2023 miss is not. — WA OFM
STEP 2
Member volume projection
OWNER
FSSA OMPP analytics + State Demographer
HANDOFF
By-program enrollment projections feed the model
WHERE IT BREAKS
Volume projections during the unwinding (Apr 2023 – Apr 2024) were complicated by procedural disenrollments and re-enrollments.
WHAT WE DON'T KNOW
Re-enrollment churn rate post-unwinding; net steady-state by program.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
PMPM cost projection
OWNER
FSSA OMPP + Milliman (actuary)
HANDOFF
Per-member-per-month cost trends by program
WHERE IT BREAKS
PMPM trends shifted post-PHE for chronic conditions, behavioral health, LTSS — and the model didn't catch the shift in 2023.
WHAT WE DON'T KNOW
Sensitivity analysis publication.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Washington publishes PMPM trend assumptions; Oklahoma invests heavily in encounter data quality as a rate-setting input. Indiana's actuary (Milliman) operates against post-2023 reformed forecasting but the published-methodology gap remains. — WA HCA · OK HCA
STEP 4
Monthly Medicaid financial reports (post-reform)
OWNER
FSSA CFO Bowling
HANDOFF
Monthly report to OMB, Senate Approps, House Ways & Means
WHERE IT BREAKS
Reports launched in 2024 give earlier signal but quality of underlying data drives quality of signal.
WHAT WE DON'T KNOW
Report variance flags; threshold for budget alarm.
PUBLIC COMMENT
FSSA launched monthly Medicaid financial reports in 2024, in direct response to the 2023 forecasting miss. — FSSA · Indiana Capital Chronicle · 2024
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Variance analysis at month-close
OWNER
FSSA CFO + OMB
HANDOFF
Variance explanation to legislative oversight
WHERE IT BREAKS
Variance attribution: volume vs PMPM vs casemix vs ratesetting vs other.
WHAT WE DON'T KNOW
Attribution methodology consistency.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Senate Approps Medicaid Oversight Committee
OWNER
Sen. Mishler (Chair) + LSA OFMA
HANDOFF
Public testimony and oversight
WHERE IT BREAKS
Oversight cadence and information access; the political feedback loop.
WHAT WE DON'T KNOW
Committee schedule; hearing transcripts availability.
PUBLIC COMMENT
Sen. Mishler (R-Mishawaka, Appropriations Chair) on the December 2025 forecast: now projecting positive annual Medicaid surplus rather than large deficit. Mishler created the Medicaid Oversight Committee after the 2023 miss; later authored a bill requiring FSSA to report data to the Committee and present annually on five-year look-back enforcement. — Indiana Senate Republicans · Inside INdiana Business · Dec 19, 2025
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Forecast revision at re-estimate
OWNER
FSSA + OMB + actuary
HANDOFF
Revised December forecast feeds next biennium
WHERE IT BREAKS
Revision must absorb H.R. 1, SEA 2, HEA 1277, EO 25-60 effects all at once for FY27–28.
WHAT WE DON'T KNOW
How each policy instrument is being absorbed into the forecast assumptions.
PUBLIC COMMENT
FY2026 Medicaid forecast: HIP 2.0 enrollment forecast 707,851; HIP expenditures $6.4B; total Medicaid bill growth 9.4% to $4.8B (FY26), 6.9% to $5.2B (FY27). Earlier (Dec 2024): the forecast revision left top lawmakers 'scared' as the program ran $1B more expensive than projected. — Yahoo News · WFYI · Inside INdiana Business · Dec 2024 – Dec 2025
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The 2023 forecast miss was not bad math — it was bad data + bad assumptions. The corrective response (monthly reporting, oversight committee, leadership changes) addressed signal cadence and political feedback, but did not yet fundamentally restructure the data layer the forecast runs on. The next high-risk re-estimate is FY27–28, which absorbs H.R. 1, SEA 2, HEA 1277, EO 25-60, and the hospital SDP reform — all of which materially affect member volume, PMPM, and rate setting. Without a comparable depth of data-layer reform, the same risk class persists.

Public signals

  • $984M underestimated FY24–25 biennium
  • OMPP Director Cora Steinmetz announced resignation December 20, 2024
  • FSSA Secretary Dan Rusyniak departed January 2025 (Holcomb → Braun transition)
  • FSSA launched monthly Medicaid financial reports in 2024
  • Senate Approps Medicaid Oversight Committee established by Sen. Mishler
  • Forecasting reform: post-2023 methodology overhaul

What we don't know yet

  • Current forecast methodology details (post-reform)
  • Sensitivity analysis publication
  • Variance attribution methodology
  • Re-enrollment churn rate post-unwinding (steady-state by program)
  • Oversight Committee hearing transcripts

What the data reveals

  • Data-layer reform — encounter quality, MCE data submission cadence, member-master consistency — is the underlying lever. Monthly reporting cadence is necessary but not sufficient.
  • Forecasting model documentation should be publishable. Public confidence requires methodology transparency.
  • FY27–28 re-estimate absorbing multiple policy changes simultaneously is the next forecast risk window. Plan for that now.
  • Sensitivity analysis on policy-instrument absorption (H.R. 1 take-up, SEA 2 exemption claim rates, etc.) is the missing methodology layer.
H8HEAT ZONE

Rose v. Becerra · HIP architecture

Federal court (Jun 27, 2024) vacated HHS 2020 reapproval of HIP 2.0. POWER accounts paused. Retroactive eligibility waiver vacated. NEMT waiver vacated. SEA 2 1115 amendment pending. The expansion vehicle for ~560K Hoosiers operates under constrained authority.

STEP 1
HIP 2.0 baseline (pre-Rose)
OWNER
FSSA OMPP
HANDOFF
1115 demonstration waiver
WHERE IT BREAKS
HIP architecture: premiums, POWER accounts, retroactive-eligibility waiver, NEMT waiver, Gateway-to-Work.
WHAT WE DON'T KNOW
Pre-Rose policy intent retention.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
Rose v. Becerra ruling (Jun 27, 2024)
OWNER
U.S. District Court
HANDOFF
Vacates HHS 2020 reapproval
WHERE IT BREAKS
Court grounds: failure to consider coverage loss as a relevant factor under APA review.
WHAT WE DON'T KNOW
Appeal status; subsequent federal court reactions.
PUBLIC COMMENT
Rose v. Becerra: U.S. District Court vacated HHS's 2020 reapproval of HIP 2.0 on June 27, 2024. The D.C. Circuit affirmed in March 2026 — HIP 2.0 remains operative except Indiana lacks authority to collect POWER premiums or to terminate HIP Plus coverage for non-payment. — U.S. District Court · D.C. Circuit · Indiana Justice Project · Jun 2024 + Mar 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
POWER accounts paused
OWNER
FSSA OMPP
HANDOFF
Member contributions ceased; cost-sharing logic suspended
WHERE IT BREAKS
POWER account is HIP's defining feature; pausing it changes the program's policy theory.
WHAT WE DON'T KNOW
Whether POWER accounts return in some form post-amendment.
PUBLIC COMMENT
POWER account contributions have been paused since the 2024 ruling; CMS December 2023 letter had said premiums would stay in the program despite documented concerns about coverage losses, though Indiana had not implemented contributions for nearly four years at that point. — CMS · Indiana Justice Project · 2023–2024
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Retroactive eligibility waiver vacated
OWNER
FSSA OMPP
HANDOFF
Standard retroactive eligibility resumed
WHERE IT BREAKS
Operationally requires IEDSS rules + claim adjudication updates.
WHAT WE DON'T KNOW
Rule-and-system update completion status.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
NEMT waiver vacated
OWNER
FSSA OMPP + MCEs
HANDOFF
Standard NEMT requirements apply to HIP
WHERE IT BREAKS
MCE contracts must accommodate NEMT obligation; MCE network capacity for NEMT.
WHAT WE DON'T KNOW
MCE NEMT operational implementation cadence.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
SEA 2 work-req amendment package
OWNER
FSSA OMPP + CMS Region 5
HANDOFF
1115 amendment under review
WHERE IT BREAKS
Approval is on the timeline-critical path for H.R. 1 implementation.
WHAT WE DON'T KNOW
Amendment language; approval conditions.
PUBLIC COMMENT
Federal H.R. 1 framework supersedes the 1115-waiver path for work requirements (work req cannot be waived via 1115). Indiana states may implement sooner through a state plan amendment. — KFF · CHCS · 2025–2026
OTHER STATES
Federal law (H.R. 1) explicitly removes the 1115-waiver route for work requirements — only state-plan amendments are available. Arkansas re-filed for a work-requirement waiver in January 2025; the pre-H.R. 1 litigation history (Stewart v. Azar invalidated KY HEALTH; Gresham v. Azar invalidated Arkansas) shapes CMS approval risk. — KFF · Arkansas Advocate · CMS
STEP 7
Architecture redesign for next procurement
OWNER
FSSA + future MCEs
HANDOFF
August 2026 RFP must reflect post-Rose architecture
WHERE IT BREAKS
RFP must specify HIP architecture without the vacated waivers; alternate cost-sharing mechanisms.
WHAT WE DON'T KNOW
Whether post-Rose HIP design is settled going into RFP.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

Rose v. Becerra didn't end HIP; it constrained its authority. The vacated waivers (premiums-as-condition, retroactive eligibility, NEMT) were the policy features that distinguished HIP from straight ACA expansion. Without them, HIP is structurally closer to standard expansion than to the Daniels-era design. The SEA 2 1115 amendment for work requirements re-opens the question of how distinctively Indiana HIP will remain. The August 2026 RFP must specify a HIP architecture; if the 1115 amendment isn't yet approved, the RFP either bets on approval or designs around it.

Public signals

  • Rose v. Becerra: U.S. District Court, June 27, 2024
  • Vacated: HHS 2020 reapproval of HIP 2.0
  • Affected: premiums-as-coverage-condition, retroactive eligibility waiver, NEMT waiver
  • POWER accounts paused (member contributions ceased)
  • HIP enrollment: ~560K
  • SEA 2 1115 amendment: pending CMS approval

What we don't know yet

  • Appeal status of Rose v. Becerra
  • Whether POWER accounts return in modified form
  • Rule-and-system update completion status (retroactive eligibility, NEMT)
  • MCE NEMT operational implementation cadence
  • SEA 2 amendment language and approval conditions
  • Post-Rose HIP architecture going into the Aug 2026 RFP

What the data reveals

  • August 2026 RFP architecture: design for the constrained Rose-era HIP, not pre-Rose HIP.
  • POWER account alternative: if Indiana wants to preserve a behavioral-health-style cost-sharing component, the design must clear APA-level scrutiny (the Rose grounds).
  • Operational completion: IEDSS rules + CoreMMIS claim adjudication + MCE NEMT — all three need to be confirmed complete on the vacated waivers.
  • Litigation hedge: contractual terms should accommodate further 1115 amendment trajectory uncertainty.
H9HEAT ZONE

SMC certification & CMS modular templates

Mandatory new SMC templates (APD · OAPD · AoA · Intake Form) for any procurement reaching CMS after July 1, 2026. Zero Indiana MES modules on the public CMS SMC repository. 90/10 DDI · 75/25 M&O federal match rides on certification.

STEP 1
Module identification & boundary design
OWNER
FSSA CIO Arrowood + CMCS DSG
HANDOFF
Module list aligned to CMS SMC framework
WHERE IT BREAKS
Current Indiana posture: monolithic CoreMMIS + IEDSS + Acentra + Sandata, not modular. Aug 2026 RFP must specify the modular partition.
WHAT WE DON'T KNOW
Module list under consideration.
OTHER STATES
Ohio and Michigan have well-developed MES modular module libraries with multiple certified modules on the public CMS SMC repository. Tennessee and North Carolina are progressing on outcomes-based certification under SHO #25-003. Indiana's zero-module posture is a meaningful gap relative to these peers. — CMS SMC Repository · SHO #25-003
STEP 2
Outcomes & metrics definition
OWNER
FSSA + CMS
HANDOFF
Outcomes-based certification (OBC) — now folded into SMC under SHO #25-003
WHERE IT BREAKS
Outcomes must be defined upstream of the RFP. Vendors must be able to certify against them.
WHAT WE DON'T KNOW
Indiana's outcome set; baseline measurement plans.
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
APD/OAPD/AoA submissions on new templates
OWNER
FSSA CIO + CMS Region 5 + CMCS DSG
HANDOFF
Federal review against new templates
WHERE IT BREAKS
July 1, 2026 deadline. Submissions before that date can use old format; after must use new.
WHAT WE DON'T KNOW
Indiana submission cadence vs deadline.
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Module build (vendor-led, under contract)
OWNER
Vendor + FSSA CIO oversight
HANDOFF
Build → test → readiness review
WHERE IT BREAKS
Modules certified BEFORE contract start get 75% M&O match from day one; later certification costs the state the difference.
WHAT WE DON'T KNOW
Vendor commitment timing in RFP responses.
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
CMS readiness review & certification visit
OWNER
CMS CMCS + state demonstration
HANDOFF
Certification decision
WHERE IT BREAKS
Certification visits are sequential; module-by-module process has a serialized timeline risk.
WHAT WE DON'T KNOW
Certification visit calendar.
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Posting to CMS SMC public repository
OWNER
CMS
HANDOFF
Public record of certified modules
WHERE IT BREAKS
Zero Indiana entries currently; needs visible progression by mid-2027.
WHAT WE DON'T KNOW
Repository update cadence.
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Enhanced FFP claim against certified modules
OWNER
FSSA CFO + CMS
HANDOFF
75% M&O claimed via CMS-64
WHERE IT BREAKS
Match math is the economics of every modernization decision; certification timing converts directly to dollars.
WHAT WE DON'T KNOW
Per-module dollar impact projection.
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

SMC certification is the federal funding leverage that determines the economics of every modernization decision. Indiana's zero-module posture on the public repository is a meaningful gap relative to peer states — and the August 2026 RFP is the inflection point. Modules specified loosely in the RFP can't be certified tightly later. Modules certified before contract start earn 75% match from day one; modules certified later cost the state the difference. The July 1, 2026 mandatory template deadline lands before RFP issuance, so RFP design must already be compliant.

Public signals

  • SMC mandatory templates effective July 1, 2026 (per CMCS guidance)
  • Zero confirmed Indiana MES modules on the public CMS SMC repository
  • Match rates: 90/10 DDI; 75/25 M&O
  • Outcomes-based certification folded into SMC per SHO #25-003
  • CMS-0057-F PA Interoperability Rule overlaps SMC certification surface

What we don't know yet

  • Indiana's module list under consideration
  • Indiana's outcome set and baseline measurement plans
  • Submission cadence vs July 2026 deadline
  • Vendor certification commitments in RFP responses
  • Per-module dollar impact projection

What the data reveals

  • RFP-design window is the only place to bake SMC certification into vendor accountability. Once contracts are signed, leverage drops.
  • Outcome definitions should be drafted now, May 2026, against CMS published guidance under SHO #25-003.
  • Module boundary design: a separate Provider Enrollment Module is the highest-leverage carve-out (per peer states).
  • Vendor commitment to certification timing should be in the RFP as evaluation criteria, not as post-contract negotiation.
H10HEAT ZONE

MDwise exit (January 1, 2026)

Indiana's homegrown MCE exits HHW, HIP, and HCC on Jan 1, 2026. Members auto-assigned to Anthem · CareSource · MHS unless they make a different selection. Largest single MCE transition in Indiana managed care history.

STEP 1
MDwise exit announcement (Nov 13, 2025)
OWNER
FSSA OMPP + MDwise
HANDOFF
Public notification + member communication strategy
WHERE IT BREAKS
Member communication clarity is the operational binding constraint.
WHAT WE DON'T KNOW
Per-member outreach receipt + comprehension rate.
PUBLIC COMMENT
FSSA decided MDwise would no longer be a Medicaid plan option after January 1, 2026, citing 'a comprehensive review of MDwise's performance and its ability to meet FSSA's standards for member services, provider support, and program accountability.' — FSSA · Indiana Capital Chronicle · The Arc of Indiana · Nov 13, 2025
OTHER STATES
Iowa 2017 — AmeriHealth Caritas exited mid-cycle, scrambling members into auto-reassignment. Indiana's MDwise exit (announced Nov 13, 2025, effective Jan 1, 2026) is the controlled-exit benchmark: 6+ weeks of open enrollment, 90-day post-cutover change window, 90-day authorization honor. The mid-cycle Iowa template is what controlled-exit prevents. — Managed Healthcare Executive · IA HHS
STEP 2
Member plan-selection window opens
OWNER
Maximus (enrollment broker)
HANDOFF
Member chooses Anthem · CareSource · MHS, or accepts auto-assignment
WHERE IT BREAKS
Plan choice burden on member; comprehension drives quality of choice.
WHAT WE DON'T KNOW
% members who actively choose vs accept auto-assignment.
PUBLIC COMMENT
Open enrollment ran November 1 – December 24, 2025. Members had a 90-day window after January 1, 2026 to switch plans. — FSSA · Indiana Medicaid · Nov 2025 – Jan 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Auto-assignment algorithm runs
OWNER
FSSA OMPP rules + Maximus
HANDOFF
Auto-assigned members allocated to remaining MCEs
WHERE IT BREAKS
Auto-assignment algorithm: family-keeping, provider continuity, geographic distribution, MCE market share.
WHAT WE DON'T KNOW
Algorithm details (proprietary); equity outcomes by demographic.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Member-record migration MDwise → new MCE
OWNER
MDwise + receiving MCE + FSSA
HANDOFF
Care plans, PAs in progress, claim history
WHERE IT BREAKS
Continuity-of-care during the migration: in-progress PAs, ongoing therapies, scheduled procedures.
WHAT WE DON'T KNOW
Care-continuity protocol; PA honor period.
PUBLIC COMMENT
Receiving MCEs (Anthem, CareSource, MHS) required to honor existing authorizations a minimum of 90 days, or until PA expiration, or until approved units exhausted — whichever first. — FSSA · The Arc of Indiana · Nov 2025
OTHER STATES
Iowa 2016 (Amerigroup dropped mid-cycle, member confusion) and Illinois HealthChoice (~700K member transition) are the most-studied recent MCO transitions. Common lessons: minimum 90-day authorization honor period (Indiana matches this), explicit cross-MCE care manager assignment continuity, provider directory reconciliation as a separate workstream, equity tracking on auto-assignment outcomes. — MACPAC · SHVS
STEP 5
Provider re-contracting
OWNER
Receiving MCEs + provider networks
HANDOFF
Network agreements re-papered or maintained
WHERE IT BREAKS
Some MDwise-only providers may not be in the new MCEs' networks.
WHAT WE DON'T KNOW
Provider network overlap analysis.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Illinois HealthChoice (2018) required receiving health plans to offer a 90-day transition period for members new to the plan PLUS a 180-day out-of-network provider transition with FFS-rate payment. The PA-honor + provider-network templates Indiana is using on MDwise track to the IL national template; the Aug 2026 RFP should specify the same minima. — IL HFS · DSCC UIC
STEP 6
Cutover Jan 1, 2026
OWNER
All parties
HANDOFF
Live operations under new MCEs
WHERE IT BREAKS
Day-one risk: card issuance, formulary access, in-process services.
WHAT WE DON'T KNOW
Day-one operational metrics.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Post-cutover monitoring
OWNER
FSSA OMPP + MCEs + advocacy partners
HANDOFF
Issues triage; corrective action
WHERE IT BREAKS
Public issue tracking; member-facing escalation channels.
WHAT WE DON'T KNOW
Issue volume; resolution time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
Influence on August 2026 RFP
OWNER
FSSA + bidders
HANDOFF
MDwise transition becomes informational input to RFP design
WHERE IT BREAKS
Lessons-learned codification: what went well, what didn't, how it shapes the RFP's transition clauses.
WHAT WE DON'T KNOW
MDwise post-mortem; documented lessons.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

MDwise's exit is the operational dry run for the August 2026 procurement transition. It's a smaller version of the same problem (member migration, provider re-contracting, care continuity, cutover) on a constrained timeline. The lessons from MDwise — what worked, what didn't — should be codified by mid-2026 because they inform the transition mechanics of the much larger 2027–2028 cutover for the new master contracts. A well-documented MDwise post-mortem is the single most useful artifact FSSA could produce in this window.

Public signals

  • MDwise exit: Jan 1, 2026 (announced Nov 13, 2025)
  • Receiving MCEs: Anthem · CareSource · MHS (across HHW, HIP, HCC)
  • MDwise was the only Indiana-headquartered MCE
  • Source: Indiana Capital Chronicle (Nov 13, 2025)

What we don't know yet

  • Per-member outreach comprehension rate
  • % members who actively chose vs accepted auto-assignment
  • Care-continuity protocol details
  • Provider network overlap analysis
  • Day-one operational metrics
  • Documented MDwise post-mortem

What the data reveals

  • Treat MDwise as the dry run. Build the post-mortem template now and capture lessons during the live cutover.
  • RFP transition clauses (member migration, provider re-contracting, care continuity, PA honor period) should be informed by MDwise — name the clauses in the RFP, don't leave them to negotiation.
  • Equity outcomes of auto-assignment should be measurable and published.
  • Receiving-MCE day-one readiness templates can be reused for the 2029 cutover.
F1PROCESS FLOW

Member application & enrollment

Application channel → IEDSS verification → eligibility decision → MCE assignment → CoreMMIS member master.

STEP 1
Application channel selected
OWNER
Applicant; optional navigator (FQHC, certified counselor)
HANDOFF
Channel-specific intake
WHERE IT BREAKS
Per-channel rate and quality varies. Paper applications take longest; portal fastest but excludes low-digital-literacy.
WHAT WE DON'T KNOW
Per-channel response time distribution.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
North Carolina ePASS consolidates Medicaid + SNAP + TANF + Child Care + LIEAP into a single statewide application portal — flatter than Indiana's per-channel approach. California BenefitsCal does the same on the West Coast. The single-application model reduces redundant data entry and is the upstream lever for ex parte success. — NC DHHS · CA DHCS
STEP 2
Application intake
OWNER
fssabenefits.in.gov (portal) · DFR call center · DFR county office · paper/mail
HANDOFF
Application routed into IEDSS workflow
WHERE IT BREAKS
Paper and call-center channels add manual data entry steps that introduce error.
WHAT WE DON'T KNOW
Per-channel data-entry error rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Document upload (if non-self-attested data needed)
OWNER
Applicant
HANDOFF
IEDSS document store
WHERE IT BREAKS
EO 25-60 ended self-attestation, raising the volume of documents required at intake.
WHAT WE DON'T KNOW
Post-EO 25-60 document volume change.
PUBLIC COMMENT
EO 25-60 (Apr 15, 2025) ended self-attestation. Where the Federal Data Hub / DWD has no record of an applicant's income, members must produce manual proof — increasing intake document volume. — Governor's Office · Apr 15, 2025
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Identity verification
OWNER
IEDSS → Federal Data Services Hub (USCIS SAVE for non-citizens)
HANDOFF
Verified / requires manual review
WHERE IT BREAKS
USCIS SAVE response variance; manual review queue.
WHAT WE DON'T KNOW
USCIS-failure manual-review rate.
PUBLIC COMMENT
SB 1 (signed by Gov. Braun March 4, 2026) mandates rigorous verification of immigration status for all Medicaid and SNAP applicants; requires the office to report compliance information to the federal government. — Indiana Senate Republicans · WSBT · Mar 4, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Income verification
OWNER
IEDSS → IRS + DWD wage data + Equifax/Work Number
HANDOFF
Verified / requires manual proof
WHERE IT BREAKS
Self-employment, gig, and cash income not in DWD; require manual proof.
WHAT WE DON'T KNOW
Share of applicants requiring manual income proof.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Arizona and New Mexico use 'gross-up' verification logic against the Federal Data Hub to reduce manual income review — a small acceptable variance avoids requiring the member to produce proof. California BenefitsCal automates self-employment income via tax records. — AHIP · CA DHCS · CMS
STEP 6
MAGI categorization (kids, pregnant, parents, expansion)
OWNER
IEDSS rules engine (Deloitte)
HANDOFF
If MAGI fails → non-MAGI branch
WHERE IT BREAKS
MAGI cliffs and 5% disregard are precision points; small errors disqualify.
WHAT WE DON'T KNOW
MAGI categorization reversal rate at appeal.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Non-MAGI evaluation (ABD, LTSS, dual)
OWNER
IEDSS + DDARS (LTSS) + functional eligibility assessment
HANDOFF
Eligibility decision
WHERE IT BREAKS
LTSS path adds LOC assessment by DDARS — a separate workflow.
WHAT WE DON'T KNOW
LTSS path completion time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
Notice generation
OWNER
IEDSS + DFR
HANDOFF
USPS mail + portal notification if opted in
WHERE IT BREAKS
Notice readability; per-program variant.
WHAT WE DON'T KNOW
Notice receipt and comprehension rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 9
Plan selection (MCE programs)
OWNER
Maximus enrollment broker
HANDOFF
Member selects Anthem · CareSource · MHS (or Humana/UHC for PathWays) or accepts auto-assignment
WHERE IT BREAKS
Choice quality varies; auto-assignment dominates in time-pressured cases.
WHAT WE DON'T KNOW
Per-program active-choice rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 10
CoreMMIS member master update
OWNER
IEDSS → CoreMMIS interface
HANDOFF
Member record created/updated; X12 834 transactions to MCEs
WHERE IT BREAKS
Interface latency between IEDSS and CoreMMIS varies; member-card issuance delays.
WHAT WE DON'T KNOW
IEDSS-CoreMMIS sync latency.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The application flow's failure modes concentrate in two places: identity/income verification (steps 4–5) and plan selection (step 9). Identity/income verification failures send applicants into a manual-proof funnel that's the same funnel that breaks renewals. Plan selection failures produce members in plans with low-quality network match for their needs, which then drives later care-access friction.

Public signals

  • EO 25-60 ended self-attestation (Apr 15, 2025)
  • fssabenefits.in.gov is the citizen front end
  • Maximus has held the enrollment broker contract since 2007
  • Federal Data Services Hub is the verification spine (IRS · SSA · USCIS SAVE · Equifax)

What we don't know yet

  • Per-channel application volume distribution
  • Manual-review queue depth at any given time
  • Post-EO 25-60 document volume change
  • Active-plan-choice rate by program
  • IEDSS-CoreMMIS sync latency

What the data reveals

  • Document-handling automation at intake is the highest-leverage upgrade.
  • Plan-selection comprehension testing would reduce downstream churn.
  • Per-channel intake quality metrics should be a public dashboard.
F2PROCESS FLOW

Renewal & redetermination

Ex parte first → pre-populated form → member response → re-verification → result. Now layered with H.R. 1 quarterly + SB 1 quarterly + SEA 2 amendment.

STEP 1
Renewal trigger fires (annual or quarterly)
OWNER
IEDSS scheduler
HANDOFF
Member added to renewal queue
WHERE IT BREAKS
Multiple-schedule overlap on the same member.
WHAT WE DON'T KNOW
Overlap rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
Ex parte attempt against existing data
OWNER
IEDSS
HANDOFF
Federal Data Hub + DWD wage + prior verification cache
WHERE IT BREAKS
National post-PHE ex parte rate ~41%; Indiana rate not public.
WHAT WE DON'T KNOW
Indiana's ex parte rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
North Carolina: 99% ex parte success during the unwinding — final procedural disenrollment rate 12%. Maine had the only lower disenrollment rate. NC's automation uses SSA + IRS + state wage databases. Indiana's ex parte rate is not publicly published but national post-PHE rate is ~41%; the gap explains why Indiana ran 78% procedural disenrollment. — KFF · NC Medical Society
STEP 3
Pre-populated form (if ex parte fails)
OWNER
IEDSS form module
HANDOFF
USPS + portal
WHERE IT BREAKS
Mail-based renewal dominates; address staleness is a known driver of procedural disenrollment.
WHAT WE DON'T KNOW
Address-staleness rate; mail-return rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Member responds via 5 channels
OWNER
Member; navigators
HANDOFF
Response channels: online · phone · paper · in-person · navigator
WHERE IT BREAKS
Phone capacity at DFR call center; rural digital access for portal.
WHAT WE DON'T KNOW
Per-channel response rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Document submission
OWNER
Member
HANDOFF
IEDSS document store
WHERE IT BREAKS
This is the step that produced the 78% procedural disenrollment rate.
WHAT WE DON'T KNOW
Per-document-type rejection rate.
PUBLIC COMMENT
Indiana's procedural disenrollment rate held at 78% as the unwinding concluded (Apr 2023 – Apr 2024) — the national average was 69%. Earlier in the unwinding the gap was wider: Indiana 85% vs national 75%. In response to early advocate feedback, Indiana's Medicaid outcomes dashboard now publishes a breakdown of procedural disenrollments. — KFF tracker · Indiana Capital Chronicle · May 2024
OTHER STATES
Arizona and New Mexico use 'gross-up' logic with the Federal Data Hub to reduce manual document review — instead of asking the member to prove income, the system accepts a small variance against the FDH data. California's CalSAWS consolidation enables 'no-touch' auto-renewals at scale. — AHIP · CMS · KFF
STEP 6
Caseworker reconciliation
OWNER
DFR caseworker (one of 92 county offices)
HANDOFF
Reconcile uploaded docs to IEDSS request
WHERE IT BREAKS
Per-county queue depth varies; new staffers being added to unchanged workflow.
WHAT WE DON'T KNOW
Per-county queue depth.
PUBLIC COMMENT
400 new eligibility checkers being hired into the existing workflow; 50 onboarded by late April 2026. Document-reconciliation queue runs across the 92 county DFR offices. — Indiana Capital Chronicle · Apr 29, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
H.R. 1 quarterly verification (HIP)
OWNER
IEDSS work-req module + DFR
HANDOFF
Compliance pass / fail / exemption
WHERE IT BREAKS
Volume math: 2.24M evaluations/year on top of annual renewals.
WHAT WE DON'T KNOW
Auto-evaluation share.
PUBLIC COMMENT
H.R. 1 quarterly work-requirement verification (HIP only). Mandatory outreach window June 30 – August 31, 2026; implementation deadline January 1, 2027. — CMS · KFF tracker · 2026
OTHER STATES
Arkansas 2018 (18,000 coverage losses in 7 months; 97% of removed people compliant or exempt) and Georgia Pathways 2023–present (2% of projected enrollment) are the only operating data points. Both indicate the work-requirement reporting layer fails procedurally, not substantively. Indiana's quarterly cadence is more demanding than either AR or GA. — NEJM · ProPublica · GAO
STEP 8
SB 1 quarterly check + immigration disclosure (eff July 2026)
OWNER
IEDSS + DFR
HANDOFF
Additional verification cycle
WHERE IT BREAKS
Another schedule overlay; same workflow.
WHAT WE DON'T KNOW
SB 1 operational implementation.
PUBLIC COMMENT
SB 1 (March 2026) also: removes 12-month eligibility period for HIP and requires semiannual renewal; changes general Medicaid renewal from 12 months to 6 months; modifies presumptive eligibility; SNAP candy/soft-drink purchase restriction. — Indiana Senate Republicans · WSBT · Paragon Health Institute · Mar 4, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 9
Notice generation
OWNER
IEDSS + DFR
HANDOFF
Continued · disenrolled · pending
WHERE IT BREAKS
Notice plain-language compliance.
WHAT WE DON'T KNOW
Notice comprehension rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 10
Disenrollment to CoreMMIS member master
OWNER
IEDSS → CoreMMIS
HANDOFF
X12 834 to MCEs
WHERE IT BREAKS
Procedural-vs-substantive disenrollment split not transparently published.
WHAT WE DON'T KNOW
Per-program split.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Iowa 2017's AmeriHealth Caritas exit auto-reassigned 215K members. Illinois HealthChoice 90-day transition template is the cleanest. Indiana's IEDSS→CoreMMIS handoff during a disenrollment event needs equivalent transparency. — Managed Healthcare Executive · IL HFS
STEP 11
Appeal pathway opens
OWNER
FSSA Hearings ALJ
HANDOFF
Aid pending if filed in time
WHERE IT BREAKS
Appeal capacity; aid-pending compliance.
WHAT WE DON'T KNOW
Appeal volume.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The renewal flow is where Indiana's biggest operational risks live, because it's the single workflow that now carries: annual renewals + H.R. 1 quarterly + SB 1 quarterly + EO 25-60 end-of-self-attestation + SEA 2 work-req checks. The 78% procedural disenrollment rate from the unwinding is the leading indicator of how much load this workflow can carry without further failure. Adding 400 staffers to the workflow without restructuring it is the most expensive way to discover the bottleneck is procedural, not capacity-related.

Public signals

  • 78% procedural disenrollment rate (Apr 2023 – Apr 2024 unwinding)
  • 400 staffers being hired; 50 onboarded late April 2026
  • EO 25-60: ended self-attestation
  • SB 1: quarterly checks + immigration disclosure (July 2026)
  • H.R. 1: quarterly work-req verification (HIP, 3-mo lookback)

What we don't know yet

  • Ex parte success rate
  • Document-rejection breakdown
  • Per-county queue depth
  • Auto-evaluation share for H.R. 1
  • Procedural-vs-substantive disenrollment split per program

What the data reveals

  • Document-matching automation is the single highest-ROI capability.
  • Per-county queue visibility is the prerequisite for load rebalancing.
  • Auto-evaluation share for H.R. 1 is the determinant of whether the workflow scales.
  • Procedural-vs-substantive transparency: publish the split.
F3PROCESS FLOW

Provider enrollment & revalidation

Apply → screen → ID assigned → MCE credential → revalidate every 5 years.

STEP 1
Apply via IHCP Provider Healthcare Portal
OWNER
Provider
HANDOFF
CoreMMIS provider enrollment module (Gainwell)
WHERE IT BREAKS
Portal usability for small providers; ownership-disclosure complexity for entity providers.
WHAT WE DON'T KNOW
Application abandonment rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Texas TMHP operates a single provider portal that funnels into all managed-care plans. Colorado and Arizona were early adopters of CMS PECOS integration patterns reducing duplicate disclosure burden. NCQA has a standardized credentialing framework states could adopt for cross-MCE reciprocity. — TX HHSC · TMHP · NCQA
STEP 2
NPI · taxonomy · license · ownership disclosure submitted
OWNER
Provider
HANDOFF
Verification against state license boards + CMS NPI registry
WHERE IT BREAKS
Ownership disclosure is the integrity hook; gaps in disclosure are pattern-detectable.
WHAT WE DON'T KNOW
Disclosure-failure rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
CMS risk-level screening (§455.450)
OWNER
Gainwell + FSSA OPI
HANDOFF
Limited / moderate (adds unannounced site visit) / high (adds fingerprint background for provider and 5%+ owners)
WHERE IT BREAKS
Site-visit completion rate for moderate-risk providers; fingerprint completion for high-risk.
WHAT WE DON'T KNOW
Per-risk-level completion timeline.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Exclusion list checks
OWNER
Gainwell + FSSA OPI
HANDOFF
LEIE (monthly) · SAM.gov · Indiana exclusion list · §455.417 cross-state
WHERE IT BREAKS
§455.417 cross-state termination cascade — compliance not publicly characterized.
WHAT WE DON'T KNOW
Cross-state termination handling rate.
PUBLIC COMMENT
Background-check gaps were among 'multiple issues' identified in the FSSA attendant-care audit findings — implicating the provider-screening pipeline (LEIE/SAM/state exclusion list/§455.450 risk levels). — FSSA audit findings · Indiana Capital Chronicle · Apr 23, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Internal Medicaid provider ID assigned
OWNER
Gainwell (CoreMMIS provider master)
HANDOFF
Provider activated in claims system
WHERE IT BREAKS
Activation latency from application to first-claim-eligible date.
WHAT WE DON'T KNOW
Activation latency.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Texas TMHP operates a single provider portal that funnels enrollment into all four STAR programs. Arizona AHCCCS has a single provider master across acute + LTSS programs. Indiana's CoreMMIS provider master + 5 separate MCE credentialing processes is the national majority pattern but the cost is provider directory accuracy. — TX TMHP · AZ AHCCCS
STEP 6
MCE credentialing (separate process per MCE)
OWNER
Each of 5 participating MCEs
HANDOFF
Provider added to MCE network
WHERE IT BREAKS
Credentialing duplication: same provider, 5 MCE credentialing processes.
WHAT WE DON'T KNOW
Cross-MCE credentialing reciprocity efforts.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Few states have implemented cross-MCE credentialing reciprocity at scale, but New York's CAQH integration is the closest national model. NCQA's Credentialing Verification Organization standard is the reciprocity scaffold. Indiana's five separate MCE credentialing processes are the national norm — but the cost is provider directory accuracy. — NCQA · CAQH · NY DOH
STEP 7
Service delivery & claim submission begins
OWNER
Provider
HANDOFF
Into F4 (claims) or F5 (managed care)
WHERE IT BREAKS
First-claim error rate for newly enrolled providers.
WHAT WE DON'T KNOW
First-90-day error rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
Revalidation every 5 years (§455.414)
OWNER
Provider + FSSA OPI + Gainwell
HANDOFF
Refreshed disclosures + screening
WHERE IT BREAKS
Revalidation queue is where dormant or non-compliant providers can be identified.
WHAT WE DON'T KNOW
Revalidation completion rate; per-cycle de-enrollment rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

Provider enrollment is where Indiana's integrity exposure begins. The two recent audits (ABA, attendant care) suggest the screening + ownership-disclosure layer is where the leakage starts. Cross-state termination cascade (§455.417) compliance is the highest-leverage cleanup. MCE credentialing duplication is a member-experience friction that affects access; provider directory accuracy depends on it.

Public signals

  • Five participating MCEs across the four programs
  • Revalidation cycle: every 5 years per §455.414
  • CMS risk-level screening per §455.450
  • Two recent integrity audits (ABA, attendant care) point to documentation/ownership surface

What we don't know yet

  • Application abandonment rate
  • Site-visit and fingerprint completion rates
  • §455.417 cross-state termination cascade compliance
  • Activation latency
  • Cross-MCE credentialing reciprocity
  • Revalidation completion rate

What the data reveals

  • Ownership-disclosure depth is the leverage point for integrity. Pre-payment.
  • Cross-state termination cascade compliance should be auditable and reported.
  • MCE credentialing reciprocity would reduce provider friction and improve directory accuracy.
F4PROCESS FLOW

Service delivery & claims (FFS)

Verify eligibility → deliver service → submit 837 → CoreMMIS adjudicates → 835 remit → post-payment review.

STEP 1
Eligibility verified at point of service
OWNER
Provider; portal or 270/271 EDI
HANDOFF
Eligibility confirmation
WHERE IT BREAKS
Cached vs real-time eligibility; portal latency.
WHAT WE DON'T KNOW
% providers using portal vs 270/271.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
Service delivered; encounter/claim built
OWNER
Provider + EHR/billing system
HANDOFF
X12 837 generated
WHERE IT BREAKS
Documentation practices vary by provider class; audit surface (see H4).
WHAT WE DON'T KNOW
Documentation-defect rate by service line.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Claim submitted via clearinghouse
OWNER
Provider/clearinghouse (Availity · Optum · Waystar · Inovalon)
HANDOFF
CoreMMIS claim ingestion
WHERE IT BREAKS
Per-clearinghouse error rates and reject patterns vary.
WHAT WE DON'T KNOW
Direct-submission share vs clearinghouse share.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Front-end edits (CoreMMIS)
OWNER
Gainwell
HANDOFF
X12 999 + 277CA responses
WHERE IT BREAKS
Edit version control opaque; edit changes can shift rejections.
WHAT WE DON'T KNOW
Edit rejection rate; edit change cadence.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Washington's ProviderOne MMIS modernization (2010–present) is a published case study in incremental MMIS replacement. California's xDR modernization replaced the legacy MMIS over multiple modular phases. Indiana's CoreMMIS (1991, 35-year lineage) is on the older end of the country. — WA HCA · CA DHCS · GAO-20-179
STEP 5
Adjudication
OWNER
Gainwell + FSSA OMPP (fee schedule, PA cross-check, TPL/COB, eligibility)
HANDOFF
Clean claims auto-adjudicate; failed-edit claims suspend
WHERE IT BREAKS
Suspended-claim queue is the manual workaround layer.
WHAT WE DON'T KNOW
Suspension rate; resolution time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Pre-payment clinical edits and EVV validation at submit are increasingly common — NM, SC, and NY OMIG-aligned states catch documentation issues earlier. Indiana's suspended-claim queue (the 13th-layer manual workaround) is the symptom of the post-payment posture. — NM HSD · SC DHHS · NY OMIG
STEP 6
Suspended-claim resolution
OWNER
Gainwell + FSSA OMPP
HANDOFF
Resolved / denied
WHERE IT BREAKS
Manual workload; provider follow-up workflow.
WHAT WE DON'T KNOW
Suspended-claim queue depth.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Payment EFT + X12 835
OWNER
Gainwell + state treasury
HANDOFF
Provider remit
WHERE IT BREAKS
Prompt-pay compliance: 90% in 30 days, 99% in 90 days (42 CFR §447.45).
WHAT WE DON'T KNOW
30-day vs 90-day compliance rate.
PUBLIC COMMENT
HEA 1474 set standards for how quickly an MCO must pay, deny, or suspend a claim — plus interest owed when deadlines are missed. Legislative response to PathWays provider claim-processing complaints. — WFYI · Indiana Public Media · Jun 2025 (Roob testimony) – 2026
OTHER STATES
Wisconsin and Pennsylvania publish prompt-pay performance against 42 CFR §447.45 (90% in 30 days, 99% in 90 days) on public dashboards. Indiana's HEA 1474 (2025) established MCO-side prompt-pay standards but the public-dashboard piece isn't yet implemented. — WI DHS · PA DHS · WFYI
STEP 8
Post-payment review
OWNER
FSSA OMPP + UPIC + PERM contractor + MFCU
HANDOFF
Recoupment / extrapolation / referral
WHERE IT BREAKS
This is the audit step. ABA + attendant care concentrated here.
WHAT WE DON'T KNOW
Per-service-line audit rate; finding sustain rate.
PUBLIC COMMENT
Two active integrity audits sit at this step. ABA: $56M confirmed + $76.7M potentially improper (HHS OIG 2024). Attendant care: $200M sought from 5 largest providers (FSSA Apr 2026). FSSA said it is 'expanding oversight to more providers.' — HHS OIG · Indiana Capital Chronicle · Dec 2024 / Apr 2026
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The FFS claim flow's weak points are at steps 4–6 (front-end edits, adjudication, suspended-claim resolution) and step 8 (post-payment review). Edits catch some errors at submit; the suspended-claim queue carries the rest into manual handling. Post-payment review (H4) is where the audit exposure surfaces. Pre-payment integrity logic (edit + EVV validation at submit) is the highest-leverage upgrade for both throughput and integrity.

Public signals

  • Prompt-pay: 42 CFR §447.45 (90% in 30 days, 99% in 90 days)
  • CoreMMIS has been the claims engine since 1991 (HP → DXC → Gainwell)
  • ABA audit (HHS OIG, 2024) + attendant care audit (FSSA, April 2026) — both post-payment findings
  • PERM cycle ~26 months sample → result

What we don't know yet

  • Edit rejection rate and edit-version cadence
  • Suspended-claim queue depth
  • 30-day vs 90-day prompt-pay compliance
  • Per-service-line audit rate
  • PERM eligibility-component contribution to Indiana's rate

What the data reveals

  • Pre-payment integrity logic at submit is the highest-leverage capability — catches at $0 cost vs post-payment recoupment.
  • Suspended-claim queue visibility should be a public metric.
  • Prompt-pay compliance reporting cadence should be monthly.
F5PROCESS FLOW

Managed care operations

Rate setting → capitation → MCE adjudicates → encounter submission → reconciliation → quality + network adequacy → contract performance.

STEP 1
Rate setting against encounter data
OWNER
FSSA OMPP + Milliman (actuary)
HANDOFF
Certified capitation rates
WHERE IT BREAKS
Rate setting quality depends on encounter quality. PathWays year-2 encounter quality is the highest-risk input.
WHAT WE DON'T KNOW
Actuarial confidence interval per program.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Washington publishes actuarial methodology + sensitivity analysis. Oklahoma has invested heavily in encounter data quality as a rate-setting input. North Carolina ties capitation withholds to MCE outcomes (NC Tailored Plans). — WA HCA · OK HCA · NC DHHS
STEP 2
Capitation payment to MCEs (X12 820)
OWNER
FSSA + state treasury
HANDOFF
Monthly capitation flows to Anthem · CareSource · MHS · Humana · UHC
WHERE IT BREAKS
Capitation accuracy depends on member-master accuracy (IEDSS → CoreMMIS).
WHAT WE DON'T KNOW
Capitation reconciliation cycle time.
PUBLIC COMMENT
PathWays NF capitation-cycle delays of $462M (Feb–Apr 2026) reflect end-to-end friction in this step — state → CMS → MCE on a still-new contract structure. — Indiana Capital Chronicle · Skilled Nursing News · Apr 8, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
MCE adjudicates member claims
OWNER
MCE claims systems (each MCE separately)
HANDOFF
Payment to MCE-contracted providers
WHERE IT BREAKS
Per-MCE claim adjudication policy variance; same service, different MCE handling.
WHAT WE DON'T KNOW
Per-MCE PA approval rates; denial rates.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Encounter data submission to CoreMMIS
OWNER
MCEs → CoreMMIS encounter ingestion
HANDOFF
Encounter file ingestion (often batch flat-file)
WHERE IT BREAKS
Encounter file reject rates; resubmission cycle. Sub-capitation to delegated providers loses encounter visibility.
WHAT WE DON'T KNOW
Per-MCE encounter quality scores; sub-cap arrangements.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Sub-capitation arrangements are common nationally but rarely contractually visible to states. North Carolina requires sub-cap disclosure in its Tailored Plans contracts — the most transparent model. New York requires sub-cap arrangements be reported through encounter data with delegated-provider flags. — NC DHHS · NY DOH
STEP 5
Encounter reconciliation
OWNER
FSSA + Gainwell
HANDOFF
Reconciled encounter dataset for analytics + reporting
WHERE IT BREAKS
Reconciliation lag; data quality affects T-MSIS and forecasting.
WHAT WE DON'T KNOW
Reconciliation cycle time; data-quality scoring.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Ohio is a national leader on T-MSIS data quality scores. Indiana's T-MSIS DQ scoreboard is not public; OH publishes its scorecard tracking. — OH DOM · CMS T-MSIS DQ
STEP 6
MCE quality reporting + network adequacy
OWNER
MCEs + FSSA + NCQA accreditation
HANDOFF
Quality metrics (HEDIS, CAHPS); network adequacy reports
WHERE IT BREAKS
Behavioral health network adequacy is the most-failed access category nationally; Indiana all-92-counties shortage areas amplifies it.
WHAT WE DON'T KNOW
Per-MCE specialty network depth.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
NC Standard Plan withhold program launched 2024 — capitation withholds tied to quality measure performance, with funds returned to MCEs based on annual cycle results. Tailored Plan withhold is planned but not yet implemented. NC publishes the methodology. Most states pay capitation flat and reconcile retroactively. — NC DHHS · NC Medicaid
STEP 7
Contract performance review
OWNER
FSSA OMPP
HANDOFF
Sanctions, withholds, corrective action plans
WHERE IT BREAKS
Performance-to-payment linkage — capitation withholds tied to encounter quality?
WHAT WE DON'T KNOW
Per-MCE withhold history.
PUBLIC COMMENT
FSSA cited 'comprehensive review of MDwise's performance and its ability to meet FSSA's standards for member services, provider support, and program accountability' as the basis for the MDwise exit (Jan 1, 2026). — FSSA · Indiana Capital Chronicle · Nov 13, 2025
OTHER STATES
North Carolina Tailored Plans tie capitation withholds to encounter data quality + outcomes — the single highest-leverage MCE accountability mechanism in the country. Most states pay capitation flat and reconcile retroactively. — NC DHHS · MACPAC

Diagnosis

Managed care operations' binding constraint is encounter data quality. Rate setting, forecasting, MCE accountability, and federal reporting all depend on it. Sub-capitation arrangements between MCEs and large delegated provider groups are a known national gap in encounter visibility; in Indiana it's not publicly characterized. Capitation withholds tied to encounter quality are the single highest-leverage contract mechanic.

Public signals

  • Five MCEs across the four programs (Anthem · CareSource · MHS · Humana · UHC)
  • MDwise exits Jan 1, 2026
  • PathWays launched Jul 1, 2024
  • Behavioral health network adequacy: all 92 counties shortage areas

What we don't know yet

  • Per-MCE PA approval and denial rates
  • Per-MCE encounter quality scores
  • Sub-capitation arrangements with delegated providers
  • Reconciliation cycle time
  • Per-MCE specialty network depth
  • Withhold history

What the data reveals

  • Encounter data quality is the single most consequential operational metric.
  • Sub-capitation visibility should be contractually required.
  • Capitation withholds tied to encounter quality is the highest-leverage RFP clause.
  • Behavioral health network adequacy needs separate operational tracking.
F6PROCESS FLOW

Prior authorization

FFS: Acentra Atrezzo. Managed care: each MCE. CMS-0057-F decision timeframes (Jan 2026) and FHIR PA API (Jan 2027).

STEP 1
Provider determines PA needed
OWNER
Provider / EHR
HANDOFF
PA request initiated
WHERE IT BREAKS
PA criteria knowledge varies by provider class.
WHAT WE DON'T KNOW
PA-needed misidentification rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
PA submission
OWNER
Provider → Acentra Atrezzo (FFS) OR MCE portal (managed care)
HANDOFF
PA enters review queue
WHERE IT BREAKS
Each MCE has its own portal; provider must navigate 5 different systems. CMS-0057-F FHIR PA API requires a unified standard.
WHAT WE DON'T KNOW
PA submission error rate by destination.
PUBLIC COMMENT
CMS-0057-F operational provisions began January 1, 2026: 72-hour expedited and 7-day standard PA decisions for all impacted payers. — CMS-0057-F final rule · Jan 1, 2026
OTHER STATES
Oklahoma's FHIR Plan-Net pilot (Sep 2024 launch) is the early state implementation of CMS-0057-F's interoperability provisions. California's AB-3030 (the 'AI in PA' law) limits AI-driven denials. Indiana hasn't publicly committed to a FHIR readiness pathway for the August 2026 RFP. — OK HCA · CA Legislature · CMS-0057-F
STEP 3
Clinical review
OWNER
Acentra clinical reviewers / MCE UM team
HANDOFF
Approve / deny / request additional info
WHERE IT BREAKS
Review timeliness; clinical criteria source-of-truth.
WHAT WE DON'T KNOW
Per-MCE review cycle time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Decision notification
OWNER
Acentra / MCE
HANDOFF
Provider + member notified
WHERE IT BREAKS
CMS-0057-F sets decision timeframes from Jan 1, 2026.
WHAT WE DON'T KNOW
Pre-vs-post CMS-0057-F decision timing.
PUBLIC COMMENT
By March 31, 2026 every impacted payer was required to publish CY2025 PA metrics (approval/denial rates, appeal outcomes, average decision timeframes) on its public-facing website. — CMS-0057-F final rule · Mar 31, 2026
OTHER STATES
CMS-0057-F required ALL impacted payers to publish CY2025 PA metrics on their public websites by March 31, 2026 — including approval/denial rates, appeal outcomes, average decision timeframes. Indiana MCEs should have these live; this is a check-and-publish moment, not a future deadline. — CMS-0057-F final rule
STEP 5
Denial → appeal pathway
OWNER
MCE internal appeal first; then state fair hearing (F9)
HANDOFF
Into F9
WHERE IT BREAKS
Appeal exercise rate; denial pattern by service line.
WHAT WE DON'T KNOW
Per-MCE denial appeal rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Medicare's WISeR PA AI pilot launches January 2026 in six states (AZ, NJ, OH, OK, TX, WA), running through 2031. California's AB-3030 limits AI-driven denials. Indiana hasn't publicly engaged with the AI-in-PA frontier. — STAT · CMS · CA Legislature
STEP 6
Authorization issued; care proceeds
OWNER
Provider
HANDOFF
Service delivered under PA
WHERE IT BREAKS
PA-honored period for cross-MCE transitions (MDwise exit).
WHAT WE DON'T KNOW
PA honor period during MCE transitions.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Claim submission with PA reference
OWNER
Provider
HANDOFF
Into F4/F5; PA cross-check at adjudication
WHERE IT BREAKS
PA-claim match logic; PA expiration handling.
WHAT WE DON'T KNOW
PA-match failure rate at adjudication.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

PA is the most-cited provider burden in Medicaid nationally and the same applies in Indiana. CMS-0057-F's January 2027 full FHIR PA API requirement is the major operational milestone — it forces standardization across MCE systems plus Acentra. Pre-FHIR, providers navigate 5 different MCE portals plus Atrezzo, multiplying friction. The MDwise transition creates a near-term PA-honor question.

Public signals

  • Acentra Health holds FFS PA/UM since July 1, 2023
  • CMS-0057-F decision timeframes: January 1, 2026
  • CMS-0057-F full FHIR PA API: January 1, 2027
  • Each of 5 MCEs runs its own PA portal for managed care

What we don't know yet

  • Per-MCE review cycle time
  • Per-MCE denial and appeal rates
  • Pre-vs-post CMS-0057-F decision timing
  • PA honor period during MCE transitions
  • PA-match failure rate at adjudication

What the data reveals

  • FHIR PA API readiness is a 2027 deadline that must be in the August 2026 RFP.
  • PA standardization across MCEs is a member-experience and provider-experience upgrade.
  • MDwise transition PA-honor period should be set explicitly.
F7PROCESS FLOW

Pharmacy

Traditional Medicaid (FFS): OptumRx. HHW/HIP/HCC/PathWays: MCE PBM. MDRP rebate invoicing through Gainwell.

STEP 1
Prescription written
OWNER
Prescriber
HANDOFF
Pharmacy electronic transmission
WHERE IT BREAKS
PDL knowledge varies; off-PDL prescribing requires PA.
WHAT WE DON'T KNOW
PDL adherence rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
Pharmacy claim adjudication
OWNER
OptumRx (FFS) OR MCE PBM (managed care)
HANDOFF
Real-time claim approval / PA / denial
WHERE IT BREAKS
PA path adds friction; specialty drugs through medical benefit go to Acentra (FFS).
WHAT WE DON'T KNOW
Specialty drug split between pharmacy and medical benefits.
PUBLIC COMMENT
FSSA proposed (Feb 2026) to end Medicaid reimbursement for drugs purchased through the 340B program, effective July 1, 2026. Savings estimate rose from $20M to ~$60M annually. FQHCs exempted May 1, 2026 after pushback; hospitals still affected. — Indiana Capital Chronicle · WISH-TV · 340B Report · Feb – May 2026
OTHER STATES
Two distinct national models: California Medi-Cal Rx (Jan 2022) and New York NYRx (April 2023) carved pharmacy fully OUT of managed care to a single state-administered FFS contractor (Magellan in CA). Outcomes uncertain — Medi-Cal Rx 'increased budget volatility and uncertainty,' initial savings projections 'not validated by actual data.' Ohio took a middle path: a single state-controlled PBM (Gainwell, since Oct 1, 2022) keeping managed care intact — $140M saved over 2 years, 1,200% boost in dispensing fees, 99% pharmacy network. Indiana's August 2026 RFP could specify either model. — CA DHCS · NY DOH · OH DOM · Ohio Capital Journal · LAO 5026
STEP 3
Member receives medication
OWNER
Pharmacy
HANDOFF
Dispensing event
WHERE IT BREAKS
Co-pay collection; member affordability.
WHAT WE DON'T KNOW
Co-pay-related abandonment rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Pharmacy submits claim for payment
OWNER
Pharmacy → PBM/Gainwell
HANDOFF
Payment to pharmacy
WHERE IT BREAKS
Pharmacy reimbursement rates vary by program.
WHAT WE DON'T KNOW
Per-program pharmacy rates.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
California Medi-Cal Rx (Magellan-operated state FFS) added a 2026 requirement: prescribers must enroll in Medi-Cal FFS using NPI Type 1 (effective June 26, 2026); pharmacies must submit ICD-10 diagnosis codes on adjudications (effective fall 2026). NY NYRx and OH Single PBM operate without these requirements. Indiana's August 2026 RFP could specify any of these models. — CA DHCS · NY DOH · OH DOM
STEP 5
MDRP rebate invoicing
OWNER
Gainwell (FFS) + MCEs (managed care) → manufacturer
HANDOFF
Rebate collected and returned
WHERE IT BREAKS
Rebate accuracy depends on claim data quality; 340B claim flagging is critical.
WHAT WE DON'T KNOW
340B duplicate-discount rate.
PUBLIC COMMENT
Roob: 'Indiana Medicaid relies heavily on drug rebate revenue to help fund the program, and when claims run through 340B, the state loses those rebates. These entities bill Medicaid far above their discounted acquisition cost.' Advocates: change will 'erode Indiana's safety net.' — Indiana Capital Chronicle · Axios Indianapolis · Mar – May 2026
OTHER STATES
California and New York keep 100% of federal pharmacy rebates by operating state-administered carve-outs. Ohio's single-PBM model also captures rebate scale while preserving managed care. Indiana's current carve-IN to MCEs splits rebate flows across the five MCE PBM arrangements. — CA DHCS · NY DOH · OH DOM
STEP 6
Specialty / oncology under medical benefit
OWNER
Acentra (FFS) + MCEs (managed care)
HANDOFF
Medical-benefit PA + claims path
WHERE IT BREAKS
Medical-benefit drug PA has different mechanics than pharmacy PA.
WHAT WE DON'T KNOW
Volume of medical-benefit drug spend.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

Pharmacy carve-in vs carve-out is the policy decision that drives every operational variable. Indiana's hybrid (managed care carved IN; Traditional carved OUT) is the national majority pattern. California (Medi-Cal Rx) and New York (NYRx) moved the opposite direction to capture rebate scale and eliminate PBM spread. Indiana has not made that move; the August 2026 RFP is the next decision window.

Public signals

  • OptumRx is FFS / Traditional pharmacy
  • Pharmacy carved IN to managed care for HHW/HIP/HCC/PathWays
  • California and New York carved pharmacy OUT to state-run model in 2022–2023
  • MDRP rebate invoicing through Gainwell

What we don't know yet

  • PDL adherence rate
  • Per-program pharmacy rates
  • 340B duplicate-discount rate
  • Specialty drug split (pharmacy vs medical benefit)
  • Co-pay-related abandonment rate

What the data reveals

  • Pharmacy carve-out is a strategic policy lever — the Aug 2026 RFP could specify a state-run pharmacy model.
  • 340B claim flagging accuracy directly affects rebate revenue.
  • Specialty drug oversight is split between pharmacy and medical benefit paths; clinical oversight differs.
F8PROCESS FLOW

LTSS / HCBS / EVV

Functional eligibility → care plan → service delivery → EVV → claim → MCE adjudicates (PathWays) or CoreMMIS (FFS waivers).

STEP 1
Functional eligibility / Level of Care
OWNER
DDARS assessor + AAA
HANDOFF
Eligibility decision
WHERE IT BREAKS
Assessment tool reliability; inter-rater agreement.
WHAT WE DON'T KNOW
Inter-rater reliability score.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Arizona ALTCS — the first statewide capitated managed-LTSS system (acute care 1982; LTSS expansion 1988) — uses a single integrated functional + financial assessment. Indiana's PathWays is in year 2; AZ has 40 years of operational maturity to draw from. — AZ AHCCCS · PubMed (Health Care Financing Review)
STEP 2
Care planning
OWNER
MCE care manager (PathWays) OR DDARS (FFS waivers)
HANDOFF
Plan of care + authorized services
WHERE IT BREAKS
Care plan quality and timeliness; per-MCE care manager caseload.
WHAT WE DON'T KNOW
Per-MCE caseload; turnaround time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Service delivery
OWNER
HCBS provider · attendant care provider · nursing facility
HANDOFF
Service rendered; encounter built
WHERE IT BREAKS
Attendant care providers are the H4 audit surface.
WHAT WE DON'T KNOW
Per-service-line encounter quality.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
EVV capture
OWNER
Provider EVV system → Sandata aggregator
HANDOFF
EVV record posted
WHERE IT BREAKS
Real-time capture; batch reconciliation to claim.
WHAT WE DON'T KNOW
EVV-to-claim match rate.
PUBLIC COMMENT
Sandata is the Indiana EVV state aggregator, integrated with CoreMMIS via Gainwell. Open vendor model — alternates must export to the Sandata Aggregator. Provider-side training via Sandata Learn LMS. — in.gov/medicaid · Indiana Medicaid Provider · current
OTHER STATES
Sandata is the most-deployed state EVV aggregator (Indiana, TX, PA, others). Texas runs the most mature EVV reconciliation; Pennsylvania's CHC EVV ties to managed-LTSS contracts more directly. Real-time EVV-claim reconciliation (not batch) is the leadership benchmark — few states have implemented it. — Sandata · TX HHSC · PA DHS
STEP 5
Claim submission
OWNER
Provider / clearinghouse
HANDOFF
PathWays MCE adjudicates OR CoreMMIS for FFS waivers
WHERE IT BREAKS
Sub-capitation in PathWays may obscure delegated-provider claims.
WHAT WE DON'T KNOW
Sub-cap arrangements in PathWays.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Payment
OWNER
MCE OR CoreMMIS
HANDOFF
EFT + 835
WHERE IT BREAKS
PathWays NF payment cycle delays (H5: $462M Feb–Apr 2026).
WHAT WE DON'T KNOW
Per-NF payment-delay distribution.
PUBLIC COMMENT
$462M in delayed NF payments across 496 facilities (Feb–Apr 2026); Roob: 'I never would have pursued this program.' Program running $300M+ over budget. — Indiana Capital Chronicle · WFYI · Apr 8, 2026
OTHER STATES
Pennsylvania Community HealthChoices (since 2018) does NOT have $462M-class quarterly NF payment delays — the methodology is stable. Tennessee CHOICES NF payment cycle is also stable. The Indiana delay is a year-1–2 managed-LTSS friction pattern that should normalize unless H.R. 1 disrupts the methodology. — PA DHS · TN DHHS
STEP 7
Encounter to CoreMMIS / analytics
OWNER
PathWays MCEs → CoreMMIS
HANDOFF
Encounter ingestion (often batch flat-file)
WHERE IT BREAKS
Year 1–2 encounter quality structurally weak (H5).
WHAT WE DON'T KNOW
PathWays encounter reject rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
Pennsylvania Community HealthChoices (2018 launch) has documented encounter-data-quality benchmarks across 7+ years of operation. Arizona ALTCS has 38 years of operational maturity on encounter feedback loops. Indiana's PathWays is in year 2 — the encounter quality structural weakness is age-of-program, not vendor performance. — PA DHS · AZ AHCCCS
STEP 8
Rate setting feedback loop
OWNER
FSSA + Milliman
HANDOFF
Next-cycle rates
WHERE IT BREAKS
Encounter quality drives rate accuracy; weak encounter → weak rates → repeat.
WHAT WE DON'T KNOW
Actuarial confidence interval.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
HCBS waiver waitlists exist in 40 states (KFF 2024). Average wait is 40 months. The South has 3/4 of all waitlisted people — some wait 10+ years. Olmstead v. L.C. (1999) is the legal mechanism for ADA enforcement; Indiana's ACLU 2024 S.D. Indiana class action follows the pattern. — KFF · MACPAC · Olmstead v. L.C.
STEP 9
HEA 1277 long-stay carve-out (eff 7/1/2027)
OWNER
FSSA + General Assembly
HANDOFF
Long-stay (>100d) returns to FFS
WHERE IT BREAKS
Transition mechanics for long-stay members; provider re-contracting.
WHAT WE DON'T KNOW
Transition plan details.
PUBLIC COMMENT
HEA 1277 (Rep. Brad Barrett, R-Richmond, author; Sen. Mike Crider, R-Greenfield, sponsor) signed March 12, 2026 — long-stay (>100 days) carve-out from PathWays effective July 1, 2027; FSSA must file standalone assisted-living waiver application with CMS by September 1, 2026. — Indiana HCA · OPEN MINDS · Mar 12, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

LTSS / HCBS / EVV concentrates all of Indiana's hottest operational risks: encounter quality (PathWays year 2), provider integrity (attendant care audit, H4), payment cycle (NF $462M delays), and waitlist (intake throughput). EVV reconciliation is the single fork that determines audit defensibility, payment accuracy, and rate-setting quality.

Public signals

  • PathWays launched Jul 1, 2024
  • PathWays MCEs: Anthem · Humana · UHC
  • Sandata is state EVV aggregator (open vendor model)
  • HEA 1277 long-stay carve-out: effective Jul 1, 2027
  • 11,296 waiver waitlist (Feb 2026)
  • $462M delayed NF payments (Feb–Apr 2026)

What we don't know yet

  • Inter-rater reliability on LOC assessment
  • Per-MCE care manager caseload
  • EVV-to-claim match rate
  • Sub-capitation arrangements in PathWays
  • Per-NF payment-delay distribution
  • Encounter reject rate

What the data reveals

  • Real-time EVV reconciliation (not batch) is the highest-leverage upgrade — improves audit defensibility, payment accuracy, and rate setting simultaneously.
  • PathWays encounter quality sprint in year 2 is the consequential operational intervention.
  • HEA 1277 transition planning should begin now, 14 months before effective date.
  • Waitlist intake-throughput diagnosis by AAA is the prerequisite to reducing the waitlist.
F9PROCESS FLOW

Appeals & fair hearings

Adverse notice → MCE internal appeal (managed care) → state fair hearing (ALJ) → judicial review.

STEP 1
Adverse action notice issued
OWNER
MCE (managed care) or FSSA (FFS/eligibility)
HANDOFF
60-day appeal window opens
WHERE IT BREAKS
Notice readability drives whether members exercise appeal rights.
WHAT WE DON'T KNOW
Per-notice-type appeal exercise rate.
PUBLIC COMMENT
Of 9,608 Hoosiers terminated procedurally in March 2024, members had 90 days to appeal — possible to regain coverage if new documentation showed eligibility. Notice readability drives whether appeals are exercised. — Indiana Capital Chronicle · WFYI · 2024
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 2
Internal MCE appeal (managed care)
OWNER
MCE appeals unit
HANDOFF
Appeal decision; one level required per 42 CFR §438.402
WHERE IT BREAKS
Internal appeal is the procedural gate before fair hearing; reversal rates vary by MCE.
WHAT WE DON'T KNOW
Per-MCE internal appeal reversal rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Aid pending request
OWNER
Member (+ legal aid)
HANDOFF
Services continue at state risk if filed timely (42 CFR §431.230)
WHERE IT BREAKS
Aid pending compliance is the single biggest member-protection mechanism; non-compliance is rare but costly.
WHAT WE DON'T KNOW
Aid-pending compliance rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
State fair hearing filing
OWNER
Member or representative
HANDOFF
Filed with FSSA Hearings
WHERE IT BREAKS
Filing literacy; representation rate at fair hearing.
WHAT WE DON'T KNOW
Per-program filing rate; representation rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
ALJ hearing
OWNER
FSSA Hearings ALJ
HANDOFF
Standard 90-day decision (§431.244(f)); expedited 3 working days
WHERE IT BREAKS
ALJ caseload; decision quality.
WHAT WE DON'T KNOW
ALJ caseload; decision wait time.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
New York operates an integrated external-appeals process tied to the state's overall managed care appeals; California's BHSO is the independent appeals analog. Most states (Indiana included) rely on FSSA Hearings ALJ for state fair hearings without integrated external review. — NY DOH · CA DHCS
STEP 6
Decision issued
OWNER
ALJ
HANDOFF
Affirmed / reversed
WHERE IT BREAKS
Reversal rate by program; per-issue type.
WHAT WE DON'T KNOW
Per-program reversal rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Judicial review
OWNER
State courts (Indiana Tax Court / Indiana Court of Appeals depending on issue)
HANDOFF
Court review
WHERE IT BREAKS
Judicial review rate is small but the cases that reach it set precedent.
WHAT WE DON'T KNOW
Judicial review filing rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

The appeals flow's primary failure mode is non-exercise: members don't appeal because notices aren't clear or aid-pending mechanics aren't understood. Procedural disenrollment outcomes during the unwinding likely produced an under-appeal pattern (people walked away rather than fought). Capacity is the second concern: a major H.R. 1 disenrollment wave will load FSSA Hearings.

Public signals

  • 42 CFR §438.402 — managed care internal appeal first
  • 42 CFR §431.230–231 — aid pending if filed timely
  • 42 CFR §431.244(f) — 90-day standard decision
  • FSSA Hearings handles ALJ proceedings

What we don't know yet

  • Per-notice-type appeal exercise rate
  • Per-MCE internal appeal reversal rate
  • Aid-pending compliance rate
  • ALJ caseload and decision wait time
  • Per-program reversal rate at fair hearing

What the data reveals

  • Notice readability auditing is the highest-leverage front-end intervention.
  • Aid-pending compliance monitoring should be a public dashboard.
  • ALJ capacity should be forecast against the H.R. 1 disenrollment-wave projection.
  • Per-program reversal rates would expose patterns of program design vs operational error.
F10PROCESS FLOW

Program integrity

FSSA OPI front line → audit triggers → records review → extrapolation → recoupment → MFCU referral if fraud → federal layer (OIG · UPIC · PERM).

STEP 1
Pattern detection / audit trigger
OWNER
FSSA OPI + HHS OIG + CMS UPICs
HANDOFF
Open audit case file
WHERE IT BREAKS
Detection capability: rules-based vs ML.
WHAT WE DON'T KNOW
False-positive rate.
PUBLIC COMMENT
Braun administration: 'the free lunch is over.' Pattern detection prompted the $200M attendant-care audit + ABA reforms + 340B change in a single 12-month window. — WISH-TV · Indiana Capital Chronicle · Mar 2026
OTHER STATES
New York OMIG (separate Inspector General office) is the structural separation peer. Texas OIG sits inside HHSC. California DHCS Audits & Investigations is a within-agency model. The structural choice affects investigation independence and pre-payment capability. — NY OMIG · TX HHSC · CA DHCS
STEP 2
Records request to provider
OWNER
Audit agency
HANDOFF
Records produced within statutory window
WHERE IT BREAKS
Document retention varies; small providers often lack structured retention.
WHAT WE DON'T KNOW
Records-production timeline.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
Medical record / EVV review
OWNER
Clinical reviewers
HANDOFF
Findings at service-line and beneficiary level
WHERE IT BREAKS
Documentation gaps + EVV non-compliance the common surface.
WHAT WE DON'T KNOW
Per-service-line documentation defect rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 4
Statistical extrapolation
OWNER
Audit statistician
HANDOFF
Extrapolated overpayment amount
WHERE IT BREAKS
Extrapolation methodology is the most-litigated step.
WHAT WE DON'T KNOW
Sample-size adequacy challenges.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
Findings letter / overpayment notice
OWNER
Audit agency
HANDOFF
Provider response window opens
WHERE IT BREAKS
Appeal path varies by audit type.
WHAT WE DON'T KNOW
Per-audit-type appeal exhaustion rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
Provider appeal & rebuttal
OWNER
Provider + counsel
HANDOFF
Reconsideration / hearing decision
WHERE IT BREAKS
<30% reversal nationally.
WHAT WE DON'T KNOW
Indiana-specific reversal rate.
PUBLIC COMMENT
Tendercare CEO Eric Deitchman pushed back publicly: 'I'm surprised we got listed publicly while we are working on our appeal.' Provider appeal outcomes survive contest <30% of the time nationally. — Indiana Capital Chronicle · Apr 24, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
Recoupment / settlement
OWNER
FSSA OMPP / MFCU / CMS
HANDOFF
Funds returned
WHERE IT BREAKS
Settlement-vs-litigation choice.
WHAT WE DON'T KNOW
Indiana policy.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 8
MFCU referral if fraud suspected
OWNER
FSSA OPI → AG MFCU
HANDOFF
Criminal investigation; exclusion proceedings
WHERE IT BREAKS
Referral mechanics opaque.
WHAT WE DON'T KNOW
Referral volume; declination rate.
PUBLIC COMMENT
FSSA said it is 'now expanding oversight to more providers' — signaling intent to scale audit posture without (yet) publicly addressing pre-payment vs post-payment architecture. — Indiana Capital Chronicle · Fox 59 · Apr 23, 2026
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 9
Systemic data / analytics build-out
OWNER
FSSA OPI
HANDOFF
Pattern detection improves; faster triggers
WHERE IT BREAKS
Current capability largely retrospective + rules-based.
WHAT WE DON'T KNOW
ML/AI usage in pattern detection.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
NY OMIG's 2026 work plan explicitly references 'sophisticated data analysis techniques and updated software resources' for ML-based pattern detection and outlier analysis. OK's pattern engine pilots are second-tier. Indiana's MFADS capability gap is publicly characterized; the build-out window aligns with the August 2026 RFP. — NY OMIG 2026 Work Plan · OK HCA

Diagnosis

The integrity flow's defining feature in Indiana is its retrospective posture: detect, audit, recoup. Two large audits (ABA $56M, attendant care $200M) in different service lines with the same root cause (documentation + EVV) indicate the data layer already contains the signal needed for prospective detection — but the detection layer is downstream of the spending event. Pre-payment integrity catches earlier and cheaper.

Public signals

  • ABA audit (HHS OIG, 2024): $56M confirmed + $76.7M potentially improper
  • Attendant care audit (FSSA, April 2026): $200M sought from 5 providers
  • MFCU Director Matthew Whitmire (AG Rokita)
  • Indiana OIG Jared Prentice (appointed Jan 31, 2025)
  • Governor's Medicaid Working Group (Nov 2025): ABA cap + rate recommendations

What we don't know yet

  • FSSA OPI ↔ MFCU ↔ OIG referral mechanics
  • ML/AI use in current pattern detection
  • Per-service-line documentation defect rate
  • Indiana settlement-vs-litigation policy
  • Working Group implementation status

What the data reveals

  • Pre-payment integrity is the single highest-ROI capability — catches at submit, not 18 months post-payment.
  • Audit-defensible pattern engine in concentrated service lines would shift from reactive to continuous monitoring.
  • Real-time EVV reconciliation enables pre-payment integrity logic.
  • Working Group implementation should be tracked operationally.
F11PROCESS FLOW

Federal reporting

T-MSIS monthly · CMS-64/-37/-21 quarterly · PERM cycle · FSSA monthly Medicaid financial reports (post-reform).

STEP 1
T-MSIS monthly data pull
OWNER
FSSA data team
HANDOFF
Claims · encounters · provider · TPL from CoreMMIS + eligibility from IEDSS
WHERE IT BREAKS
Data lineage: CoreMMIS + IEDSS as sources of truth; encounter quality limits T-MSIS quality.
WHAT WE DON'T KNOW
T-MSIS data quality scores from CMS DQ assessments.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
CMS released the 2025 MAC Scorecard in December 2025: an additional 4 states + 1 territory met T-MSIS quality targets under the Outcomes-Based Assessment framework versus the prior year. Indiana's standing isn't publicly disclosed in the scorecard analysis. Ohio is a published leader. — CMS · Mathematica · 2025 MAC Scorecard
STEP 2
T-MSIS submission to CMS
OWNER
FSSA → CMS T-MSIS portal
HANDOFF
Submission accepted / rejected with errors
WHERE IT BREAKS
Reject-and-resubmit cycle adds latency to downstream analytics.
WHAT WE DON'T KNOW
Reject rate by file type.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 3
CMS-64 quarterly expenditure report
OWNER
FSSA CFO Bowling
HANDOFF
MBES/CBES submission
WHERE IT BREAKS
Post-2023 reform: monthly Medicaid financial reports give earlier signal.
WHAT WE DON'T KNOW
Variance flag thresholds.
PUBLIC COMMENT
FSSA launched monthly Medicaid financial reports in 2024 in response to the 2023 forecast miss. Sen. Mishler (Approps Chair) created the Medicaid Oversight Committee in the same window. — FSSA · Indiana Senate Republicans · 2024
OTHER STATES
Washington's Medical Assistance Expenditure Forecast Workgroup (MAEFW) produces a forecast twice yearly (February + October) and reviews financial data, caseloads, primary trends, FMAP, and step adjustments in a documented methodology. Colorado implemented similar reforms after a forecast miss. Indiana's monthly reports (launched 2024) are higher cadence but variance-attribution methodology isn't published. — WA OFM · WA HCA · CO DHCPF
STEP 4
CMS-37 quarterly forward projection
OWNER
FSSA CFO + OMB
HANDOFF
Budget projection for upcoming quarters
WHERE IT BREAKS
Projection quality depends on the forecast methodology (H7).
WHAT WE DON'T KNOW
Per-program projection accuracy.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 5
CMS-21 quarterly CHIP expenditures
OWNER
FSSA CFO + CHIP program
HANDOFF
MBES/CBES Title XXI submission
WHERE IT BREAKS
Title XXI is parallel infrastructure; reconciliation with Title XIX.
WHAT WE DON'T KNOW
Cross-title reconciliation cycle.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 6
FSSA monthly Medicaid financial reports
OWNER
FSSA CFO + OMB + Senate Approps
HANDOFF
Public reports to Senate Approps + House Ways & Means
WHERE IT BREAKS
Earlier signal, but signal quality depends on data quality upstream.
WHAT WE DON'T KNOW
Variance thresholds; alarm criteria.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)
STEP 7
PERM cycle (every 3 years per state)
OWNER
Indiana sample collection + PERM contractors
HANDOFF
Results returned ~26 months later
WHERE IT BREAKS
Lag is the structural issue — actions today affect a measurement 2 years away.
WHAT WE DON'T KNOW
Indiana's RY2024/RY2025 results when reported.
PUBLIC COMMENT
Indiana's pre-PHE PERM rate of 28.8% is the political baseline cited in EO 25-60; national Medicaid PERM rate (RY2025) is 6.10%. H.R. 1 sets an October 1, 2029 federal-share repayment trigger for states above 3%. — EO 25-60 · CMS PERM cycle · 2025–2026
OTHER STATES
PERM cycle is ~26 months sample-to-result. CMS publishes annual rate-year results for each state's eligibility, fee-for-service, and managed care components. Indiana's pre-PHE 28.8% baseline (cited in EO 25-60) is from RY2019; the current cycle covers Indiana again RY2025 — results not yet published. — CMS PERM Cycle · EO 25-60
STEP 8
PERM eligibility component (highest-leverage)
OWNER
PERM contractor + FSSA OPI
HANDOFF
Eligibility error rate component
WHERE IT BREAKS
Eligibility component drives national rate; Indiana's pre-PHE 28.8% is the political baseline.
WHAT WE DON'T KNOW
Indiana's post-PHE eligibility component rate.
PUBLIC COMMENT
— (no public mention found tied to this step)
OTHER STATES
— (no specific peer-state comparison found for this step)

Diagnosis

Federal reporting flows are downstream-of-data-quality. T-MSIS, CMS-64, PERM — all only as good as the source data in CoreMMIS, IEDSS, and the MCE encounter pipelines. Post-2023 monthly reporting cadence is a signal-frequency reform; it doesn't change signal quality. The PERM cycle's 2-year lag is the structural reason eligibility documentation work must start early — H.R. 1's October 2029 trigger is set against measurements still being collected.

Public signals

  • T-MSIS monthly
  • CMS-64 / CMS-37 / CMS-21 quarterly
  • PERM cycle ~26 months sample → result
  • Indiana pre-PHE PERM rate: 28.8%; national RY2025: 6.10%
  • FSSA monthly Medicaid financial reports (since 2024)
  • H.R. 1 PERM 3% repayment trigger: Oct 1, 2029

What we don't know yet

  • T-MSIS data quality scores from CMS DQ assessments
  • Indiana's current PERM eligibility component rate
  • Per-program projection accuracy
  • Cross-title reconciliation cycle
  • Variance flag thresholds in monthly reports

What the data reveals

  • Data quality at the source (encounter quality + IEDSS verification) is the binding constraint on every federal report.
  • PERM eligibility component work must begin now — measurements completed in 2027–2028 determine the October 2029 trigger.
  • Monthly Medicaid financial reports should publish variance attribution methodology.
  • T-MSIS data quality should be a public scoreboard, not a back-office concern.