Dear DDARS Leadership and Waiver Redesign Team,

We appreciate the opportunity to provide feedback on the Medicaid Waiver Reset process and recognize the significant effort being invested to improve equity, simplify navigation, and increase flexibility for Hoosiers with disabilities. As two of the largest music therapy providers in Indiana, together serving more than 700 CIH/FSW waiver participants, we strongly support the core goals of a cross-disability waiver, needs-based tiering, and improved access to the right services at the right time. We support these goals AND want to outline recommendations that will be essential for successful implementation, equitable access, and sustainable provider capacity across Indiana.

Equal Representation on the DDARS Advisory council 

There is an urgent need for the Music Therapy Access Coalition (MTAC) to have a seat on the DDARS Advisory Council.

Although the council has indicated a desire to include additional “creative arts therapies,” not a single representative from music therapy, or any creative arts therapy discipline, is currently included. This absence leaves a significant gap in expertise at a time when the state is actively redesigning waiver services,, and shaping policies that directly affect access, workforce stability, and service equity.

As one of the largest statewide provider coalitions, MTAC brings clinical expertise, workforce insight, and real-time data on how policies impact individuals with disabilities and their families and an understanding of the sustainability of providing these crucial services.

Without MTAC’s voice at the table, decisions risk being made without the vast knowledge of the very providers delivering these services. Inclusion on the council is essential to ensuring informed, equitable, person-centered policy.

Level of Care Assessment Must Be Research-Based, Functional, and Comprehensive

We strongly support the concept of a needs-based tier and agree that level of care should drive budget allocation. However, this tool must be clinically sound and capable of capturing the real-world needs of individuals across disability types.

We recommend:

• Assessment should not be conducted over the phone.

• Assessment must be administered by trained professionals familiar with the sensory, behavioral, motor, and communication needs of individuals with IDD.

• The tool must prioritize functional needs, not only medical needs.

• Assessment items should reflect behavioral regulation, sensory processing, motor planning, engagement, communication access, and participation barriers—all of which directly affect service need.

• Because the tool will be used to determine services for a diverse population, it must be comprehensive, validated, and easily appealable.

No Caps on Music Therapy Service Hours

We recommend that the team—including therapists, family, and case manager—determine the appropriate number of weekly or monthly hours based on functional need and clinical judgment. Caps would undermine BDS's goal of providing the right service at the right intensity.

Support for a Required Music Therapy Consultation Service Before Starting Services

To ensure that families receive accurate, evidence-based information about music therapy and that referrals reflect truly identified needs, we recommend the creation of a required pre-authorization consultation meeting with a credentialed music therapist from the provider they are interested in working with. This process improves outcome alignment, reduces long-term service mismatches, and supports BDS’s goal of providing the right service at the right time.

• This consultation should be billed under a new service code.

• It provides families with clear expectations, education on the clinical nature of music therapy, and an opportunity for therapists to complete a needs-based screening aligned to the treatment domain.

• This ensures families do not “jump into music therapy,” but instead begin services with a clinically informed plan and appropriate goals.

Reinstate and Strengthen Telehealth Options for Music Therapy

We recommend reinstating telehealth as a fully equal option. For more than three years, Indiana permitted virtual music therapy under the same licensure requirements we hold today. Providers delivered effective services, families relied on this flexibility, and continuity of care improved statewide. Removing telehealth solely on the basis of licensure, after allowing it for years under identical licensure rules, creates a contradictory standard that ultimately limits access for individuals with disabilities. The decision did not reflect a clinical or compliance concern; it solely removed a proven tool. Restoring telehealth is consistent with CMS policy, responsive to family needs, and essential for expanding access, especially in rural and hard-to-staff areas. Virtual options could be limited but could ultimately be: 

• A fallback during illness, weather, or transportation barriers

• A flexible option for rural areas

• A tool that improves continuity of care

Telehealth benefits individuals who struggle with transitions, immune vulnerabilities, environmental barriers, or sensory overload. It also increases provider capacity and reduces waitlists. This in itself increases access - the goal of DDARs. 

Community Integration - Music Therapy Examples

Our clinics are intentionally designed as community spaces, not isolated treatment settings. Music therapy is delivered within an integrative model where individuals with and without disabilities receive services side by side, participate in group programming, and build relationships in shared spaces.

Our locations host inclusive activities such as integrated therapy groups, sensory-friendly community events like Sensory Santa, and open common areas that foster organic peer interaction among neurodivergent and neurotypical children and adults. Families routinely form informal support networks in our lobbies, caregivers exchange resources, and individuals build friendships that extend beyond therapy sessions. 

This model demonstrates that music therapy is not only clinical intervention—it is a community connector. As Indiana works to promote inclusion and participation, our clinics already embody that vision. Increased flexibility related to transportation service provision would further strengthen access to these community-based services and allow more families to participate in integrated care environments.

Improve Provider Choice Lists for Families

Families are overwhelmed by the provider list in its current form and often spend weeks contacting agencies that do not have openings or staff in their area. To support transparency and reduce administrative burden for both families and providers, we recommend:

• Indicating whether each provider has openings, limited openings, or a waitlist

• Listing the specific counties or service radius covered

• Listing areas of clinical specialty

• Providing families access to the BDS portal to view service availability in real time

Stronger Provider Accountability and Quality Assurance

We support BDS’s efforts to strengthen quality, consistency, and accountability across Indiana. To that end, we recommend:

• Requiring routine quality-assurance reports from providers

• Setting clear expectations for balancing direct and indirect service time over the course of care—not per month—to reflect both clinical needs and real-world fluctuations (cancellations, increased documentation needs, care coordination, etc.)

• Implementing corrective action for ongoing misuse of billing guidelines

• Requiring evidence of meaningful progress for continued service authorization

• Strengthening oversight of outcome-based documentation to ensure services remain goal-driven and clinically justified
  
  

These recommendations promote family trust, protect the integrity of the system, and ensure public dollars are used effectively, while still honoring the clinical realities of indirect work that supports high-quality care.

Rate Modernization and Reinstatement of Cost-of-Living Adjustments

We fully support a cross-disability waiver model that allows individuals to access services based on functional, developmental, behavioral, and sensory needs—not diagnostic labels. This shift reflects national best practices and expands person-centered care.

However, increased access will also increase demand. Music therapy already faces long waitlists due to low reimbursement, high travel expectations, and workforce shortages. Without updating the rate structure, families may be offered more options on paper but have fewer providers in practice.

To ensure real access—not theoretical access—music therapy rate modernization must be part of the waiver reset.

Music therapy is a clinical healthcare profession with strong evidence demonstrating improvements in:

• Communication

• Regulation

• Behavioral outcomes

• Motor development

• Social engagement

• Cognitive and adaptive functioning
  
  

Research also shows that music therapy can reduce reliance on higher-cost services, aligning with BDS’s stated goal of increasing outcomes without increasing overall Medicaid spending. However, the field of music therapy faces severe workforce shortages due to:

• Low reimbursement rates

• High travel requirements

• High caseload demand per clinician

• Limited ability to retain or recruit clinicians

Opening music therapy to all disabilities without simultaneously addressing reimbursement will significantly increase waitlists and reduce access.

We strongly urge BDS to:

• Reinstate the 2% annual cost of living adjustments to service rates

• Provide a rate increase for music therapy reflective of clinical expectations and National averages

• Consider the documentation burden associated with redesigned outcome systems
  
  

Without changes to reimbursement structures, families may have increased theoretical access with decreased actual availability of therapists.

Communication Improvements Within BDS

We encourage BDS to strengthen communication channels to providers. During this Waiver Reset process, HSRI referenced 30 stakeholder discussions; we as providers were aware of only four. To ensure meaningful engagement:

• Create a central announcement hub on the BDS/FSSA website

• Send direct alerts to all enrolled providers

• Offer clearer navigation for updates, webinars, and guidance
  
  

This will result in more accurate feedback and stronger provider alignment.

Conclusion

We appreciate the thoughtful work being done through the Waiver Reset and strongly support the initiative to create a more equitable, accessible, and functional system for Hoosiers with disabilities. Our recommendations are made in the spirit of partnership and shared commitment to evidence-based, person-centered care.

With the right structure - fair assessment, meaningful provider oversight, transparent processes, improved communication, and a stable workforce - Indiana’s redesigned waiver can meaningfully enhance outcomes across the lifespan while maintaining fiscal responsibility.

We look forward to continued collaboration and appreciate the opportunity to provide this input.

Sincerely,

Allison Thomas & Kirby Gilliam
Co-Executive Directs
Music Therapy Access Coalition Foundation