Indiana HCBS Waiver Waitlists Hit 19,821: What the Growth Means for Your Agency Revenue
Indiana's home and community-based services waitlists have swelled to 12,680 on PathWays for Aging and 7,141 on Health & Wellness as of October 2026, up sharply from the 12,777 combined total at launch in July 2024. For care agencies, the bigger operational threat is not the waitlist itself but the statewide provider enrollment moratorium that began August 1, 2026, blocking new agencies and expansions for at least six months. If you operate in Indiana, your immediate action is to secure your existing census and prepare an access-gap narrative if you need to expand.
This is not a new regulation. It is monthly operational data showing continued growth on waitlists that began in April 2024, when Indiana reached its federally approved capacity and stopped automatic enrollment.
What Happened
On July 1, 2024, Indiana split its Aged and Disabled Waiver into two programs: PathWays for Aging (serving ages 60+) and Health & Wellness (serving ages 0-59). The state allocated 39,842 slots to PathWays and 16,127 to Health & Wellness, filling most with existing participants and leaving 10,574 new PathWays slots and 2,937 new Health & Wellness slots for new enrollees.
By October 2026, the waitlists had grown:
| Waiver | October 2026 Waitlist | July 2024 Waitlist | Increase | |--------|----------------------|-------------------|----------| | PathWays for Aging | 12,680 | 9,015 | 3,665 | | Total | 19,821 | 12,777 | 7,044 |
The state has not increased slot capacity beyond the 55,969 combined slots allocated for the July 1, 2025 through June 30, 2026 waiver year.
Meanwhile, Indiana imposed an enrollment moratorium for an initial six-month period starting August 1, 2026 (running through approximately January 31, 2027), which may be extended in additional six-month increments with CMS approval, citing fraud, waste and abuse risk under federal Medicaid regulations. The moratorium blocks new provider certification and enrollment for attendant care, respite, residential habilitation, structured family caregiving, transportation, caregiver coaching, home and community assistance, wellness coordination and numerous other waiver services across PathWays, Health & Wellness, Traumatic Brain Injury, Community Integration and Habilitation, and Family Supports waivers. It also restricts existing agencies from changing ownership, adding counties, or expanding services subject to the moratorium.
Who It Affects
Existing Indiana HCBS Agencies
You can continue serving your current clients. As of October 2026, 14,122 individuals were actively served under Health & Wellness alone. You cannot expand to new service types, add counties, or change ownership without an exception. The moratorium applies to most common waiver services but excludes adult day services, pest control, assisted living, physical therapy, case management, prevocational services, benefits counseling, psychological therapy, career exploration and planning, remote supports, community transition, and specialized medical equipment and supplies.
New Agencies and Prospective Entrants
The moratorium runs for an initial six-month period starting August 1, 2026 (through approximately January 31, 2027), and may be extended in additional six-month increments with CMS approval. Providers with active enrollment applications that completed all IHCP screening requirements before August 1, 2026 may still be enrolled. Applications submitted after August 1 will be denied until the moratorium lifts.
PathWays Providers Specifically
If you serve the PathWays population, you must contract with one or more of the three PathWays managed care entities: Anthem, Humana, and UnitedHealthcare. PathWays serves Medicaid-eligible individuals ages 60+ (or 60-64 with physical disabilities) who meet nursing facility level of care and choose to remain in their homes or transition from nursing facilities.
Geographic Scope
This is Indiana only. The waiver programs, waitlists and moratorium apply exclusively to Indiana Medicaid.
Key Dates
| Date | Event | Source | |------|-------|--------| | April 2024 | Indiana reached federal capacity and implemented waitlist | | July 1, 2024 | Aged and Disabled Waiver split into PathWays and Health & Wellness; initial waitlist invitation process began | | March 25, 2026 | Personal services agency license initially required for attendant care and home and community assistance providers; subsequently modified by Bulletin BT202666 (May 7, 2026) to accept either personal services agency license or home health agency license | | July 1, 2025 | Current waiver year began (55,969 combined slots) | | July 31, 2026 | CMS approved PathWays waiver renewal through June 30, 2029 | | August 1, 2026 | Provider enrollment moratorium began | | October 2026 | Waitlist data released: 12,680 on PathWays, 7,141 on Health & Wellness | | January 31, 2027 | Earliest possible moratorium end (subject to extension) | | June 30, 2026 | Current waiver year ends |
What It Means for Your Agency
Revenue and Growth
The waitlist growth does not directly cut your revenue if you already serve waiver clients. Your existing census continues. The moratorium, however, freezes your ability to grow through new service lines or geographic expansion.
Staffing
The moratorium does not limit your ability to hire clinicians or caregivers for existing clients. It limits organizational expansion. Focus on retention. If the waitlist eventually clears and invitations accelerate, you will need staff ready to onboard new clients quickly.
Compliance
Compliance changes affect attendant care and home and community assistance providers:
- As of March 25, 2026, providers must hold either a personal services agency license or a home health agency license at enrollment and recertification. The initial requirement for only a personal services agency license was rescinded by Bulletin BT202666 (May 7, 2026).
- The moratorium itself applies unless you secure an exception. Violations—such as expanding to a new county without approval—could jeopardize your existing enrollment.
Indiana rescinded previously proposed rate adjustments for certain personal care services, removing changes shared in IHCP Bulletin BT202673. The state will revisit rate adjustments later.
What to Do Now
- Verify your personal services agency or home health agency license. If you provide attendant care or home and community assistance, confirm your license meets the March 25, 2026 requirement as modified by Bulletin BT202666. Do not wait until recertification.
- Audit your current service footprint. Document every county and service type you are certified to provide. Do not attempt to expand without submitting an exception request.
- Prepare an exception request if expansion is critical. The state will consider limited exceptions to ensure sufficient member access. You must meet all provider qualification requirements and submit a narrative explaining how your exception addresses an access gap. For ABA moratorium exception requests, email OMPPProviderRelations@fssa.in.gov.
- Monitor monthly waitlist data. Indiana publishes updates at https://www.in.gov/fssa/ddars/resources/individuals/hcbs-waiver-waiting-list-information.
- Review managed care entity contracts for PathWays clients. PathWays members are served through Anthem, UnitedHealthcare, or Humana. Ensure your contracts are current and understand each MCE's authorization and prior-approval requirements.
- Focus on retention. With no new competitors entering the market and limited new client flow, your best revenue protection is keeping current clients. Review care plans, caregiver satisfaction and service quality metrics.
- Check if moratorium affects your service mix. The moratorium excludes adult day services, assisted living, case management, physical therapy, psychological therapy, and several other services. If you offer excluded services, you may still expand those lines.
What We Don't Know Yet
Indiana has not published plans to increase slot capacity beyond the current 55,969 combined allocation. The state has not released historical monthly waitlist data, so we cannot calculate the rate of growth or project future waitlist size.
The moratorium is tied to fraud, waste and abuse risk, but the state has not disclosed specific incidents, OIG findings or investigative reports justifying the action.
We do not know how many exception requests the state has approved or what narratives succeeded. We do not know whether the moratorium will be extended beyond the initial six months.
If you operate an Indiana HCBS agency and need to track authorizations, manage caregiver schedules and bill across multiple managed care entities without per-seat fees, AgenciesForge covers waiver billing, EVV and clearinghouse in one record.