If you're an Indiana Medicaid provider, you’re likely hearing about Executive Order 25-24, but you may not yet realize how much it could impact your agency.
Let’s break it down.
In January 2025, Governor Braun signed Executive Order 25-24 to crack down on waste, fraud, and abuse in state healthcare spending. That includes a full-scale audit of Medicaid claims, especially those submitted in 2024. And yes: home and community-based providers are included.
Why FWA Is Front and Center in Home Care?
Home care billing often involves multiple data hand-offs: authorizations, EVV feeds, case notes, and invoices. Each hand-off is a point where errors or deliberate misuse can slip through. Nationwide, state and federal watchdogs report that home-and-community-based services account for a growing share of improper Medicaid payments (read more about this here). Indiana’s audit is part of a broader push to prove the state is safeguarding public funds while still expanding alternatives to institutional care.
Overview of the Audit
The audit is being led by Health Management Associates (HMA) in partnership with Indiana’s Office of Medicaid Policy and Planning (OMPP).
It includes two major components:
- A review of claims system performance, eligibility alignment, and overall utilization patterns.
- A manual audit of roughly 300 paid claims per MCE program, selected from 2024 submissions.
Claims will be closely examined for:
- Overpayments
- Upcoding or unbundling
- Missing or mismatched documentation
- Incorrect provider type or place of service
Every Medicaid provider is in scope, but special attention will be paid to:
- High-dollar claims (over $50,000)
- ABA services
- Home Health, Assisted Living, and Nursing Facility services billed under the PathWays for Aging program
All claims under review are from 2024, and all selected claims were paid (not denied). Claims for pharmacy-dispensed medications are excluded, but drugs administered in outpatient settings are included.
Timeline at a Glance
What Providers Can Do Now
You don’t have to wait for an audit notice to start preparing. In fact, agencies that act early will have a major advantage if their claims are selected for review. Here’s how to get ahead of the game:
1. Identify At-Risk Claims Now
Focus on 2024 paid claims, especially those that:
- Exceed $50,000
- Involve ABA services
- Fall under home health, assisted living, or nursing facility care
2. Locate Supporting Documentation
Start pulling the full audit trail for any high-risk claims:
- Prior authorizations
- Plan of care documents
- Visit verification logs / EVV
- Clinical notes (if applicable)
- Service delivery records (including date, time, and caregiver credentials)
Make sure the documentation supports the specific code, provider, date, and location billed.
3. Audit Your Own Claims Internally
Select a sample of 2024 claims and conduct a mock audit:
- Can you match every billed unit to documentation?
- Do modifiers and provider types align?
- Are visit logs consistent with claims submitted?
This step alone can prevent thousands in potential recoupments.
4. Centralize and Standardize Recordkeeping
If your documentation is spread across systems (scheduling, EVV, billing, etc.), now’s the time to streamline. Create a standard process for retrieving documents quickly—the audit window is tight.
5. Coordinate With Your MCE Contact
Reach out to your MCE if you’re unsure how or where to submit documentation. Make sure someone on your team is monitoring provider portal messages daily through the end of June.
6. Report Unresponsive Subcontractors
If you're waiting on documentation from a subcontractor (e.g. a staffing agency or therapist), and they won’t cooperate, let the MCE or OMPP know. The state is actively tracking unresponsive providers.
What Happens After the Audit?
Once all documentation is submitted by June 27, HMA will complete its reviews and issue a report to state leaders by November 30, 2025. Based on the findings, Indiana Medicaid may:
- Issue corrective action plans
- Tighten documentation or billing requirements
- Conduct follow-up audits in high-risk areas
Even if you aren’t selected this round, this audit is setting the tone for future Medicaid oversight.
Need Help?
Agencies that rely on Paradigm start from a stronger compliance footing. Our everyday billing workflows, documentation checks, and policy monitoring keep records consistent and gaps rare, so auditors find fewer surprises. If the state asks for more detail, we quickly assemble the right files and guidance while your team stays focused on care. Feel more secure from day one, and know deeper support is ready whenever you need it.
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