Indiana InterRAI Assessment: How to Prepare and What to Do After a Denial

In January 2026, Indiana replaced its legacy Level of Care Screening Instrument (LOCSI) with the interRAI assessment suite for evaluating whether individuals qualify for HCBS waiver services. The change was supposed to modernize clinical screening. What it produced was a sharp spike in denials — and thousands of families scrambling to understand a new system that evaluates their child's needs very differently from the old one.

What Happened With the Switch

The numbers tell the story. Under the LOCSI tool, Indiana processed 28,083 screenings between July 2025 and January 2026, with only 69 denials — a 99.8% approval rate. After the interRAI rollout in February 2026, FSSA completed 14,214 screenings through June 2026 and denied 857 individuals. The denial rate jumped from 0.2% to 6.0%, peaking at roughly 15% in the initial weeks before stabilizing as assessors gained experience with the new tool.

That jump represents real people losing access to daily care, therapy hours, respite for exhausted caregivers, and community-based supports they had received for years.

Why the InterRAI Produces More Denials

The interRAI assessment suite is a clinically validated tool used internationally. But its design creates specific vulnerabilities for the I/DD population, particularly individuals with autism, complex behavioral profiles, or fluctuating support needs.

Three-day lookback window. The interRAI asks assessors to evaluate the individual's functioning over the past three days. If those three days happened to be calm — no behavioral incidents, no elopement attempts, no meltdowns — the assessment captures a snapshot that dramatically understates the individual's typical support needs. A child who has weekly behavioral crises but happened to have a good few days before the assessment can look far more independent than they actually are.

Binary questions. Many interRAI items use yes-or-no scoring rather than the nuanced functional descriptions the LOCSI allowed. "Can the individual prepare a simple meal?" has a binary answer that obscures the difference between someone who can make toast with supervision and someone who will leave the stove on and walk away.

Automated scoring algorithms. The interRAI generates a clinical score through standardized algorithms, reducing the assessor's ability to incorporate clinical judgment. Under the LOCSI, trained BDS staff could weigh qualitative factors — the severity of behaviors, the complexity of medical needs, the family's caregiver capacity. The interRAI algorithm treats the assessment data mechanically.

How to Prepare

Preparation is the single most important factor in getting an accurate interRAI result. The assessment evaluates what the individual cannot do — not what they can do with support.

Document worst-case scenarios, not best days. Keep a log of behavioral incidents, elopement attempts, self-injurious behaviors, medical emergencies, and moments requiring physical assistance for at least 30 days before the assessment. Photographs, video clips (with appropriate consent), and written incident reports from caregivers, teachers, and therapists carry more weight than a parent's verbal description.

Prepare a written summary for the assessor. Do not rely on the assessor asking the right questions. Create a one-page summary that lists: every support the individual requires for daily activities, the frequency and nature of behavioral incidents, any safety concerns (elopement risk, pica, self-harm), and the consequences that occur when supports are withdrawn or reduced. Hand this document to the assessor at the start of the evaluation.

Request that the assessment be conducted during a typical or challenging period. If your child's most significant support needs occur during specific times (mornings, transitions between activities, unstructured time), try to schedule the assessment during one of those windows. The three-day lookback means the assessor is evaluating what they observe plus what the record shows for the preceding 72 hours — timing matters.

Bring clinical evidence. Psychological evaluations, neuropsychological testing, behavioral data from school or therapy, physician letters documenting medical complexity, and any prior LOCSI or functional assessments that established the individual's level of need. Documented clinical evidence can help explain when a favorable snapshot does not reflect the individual's typical support needs.

What to Do If You Are Denied

A level-of-care denial triggers a strict timeline. Under Indiana Administrative Code, the written appeal must be received by the FSSA Division of Family Resources or the Office of Administrative Law Proceedings by 4:30 p.m. local time within 33 calendar days from the date on the notice of agency action or the action's effective date, whichever is later. The appeal can be submitted online through the FSSA Benefits Portal, by phone to DFR customer service at 1-800-403-0864, or by mail/fax to the FSSA Document Center (PO Box 1810, Marion, IN 46952; fax: 1-888-436-9199).

The critical 10-day rule: to preserve existing waiver services, file your appeal before the effective date of the termination or reduction. Under standard notice timing, that generally means within 10 days of the notice date — in practice, within 13 calendar days of the notice's mailing date. If you file after the effective date but are still within the 33-day window, your appeal may still be valid but services may be suspended until the hearing resolves.

When filing the appeal, request your child's complete interRAI assessment record — the filled-out questionnaire, the assessor's clinical notes, and the scoring rubrics that generated the denial. Reviewing this record often reveals specific items where the assessor's scoring does not match the documented support needs, giving you concrete grounds for the fair hearing.

For detailed appeal instructions including the specific forms and strategies, see the full appeal process guide. The Indiana SSI at 18 & Adult Disability Benefits Guide includes an interRAI preparation worksheet and evidence-gathering templates designed for Indiana's current assessment system.

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