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The first step is to determine if the client has insurance, ask the client and verify eligibility in MN–ITS . You can immediately continue with the Direct Access process if there is either Medical Assistance or OO eligibility in MN–ITS.
Inform the client of their choice to continue to work with you to access services directly or to go to the county/Tribal office if their county provides comprehensive assessment service. You may need to work with the county/Tribe to re-determine financial eligibility.
Ask the client if they have had any assessments done previously, and if so, where. Have the client sign a release of information to the provider to obtain the previously completed comprehensive assessment. Review and update the assessment to determine current severity ratings. While there is no specific form or requirements for comprehensive assessment update documentation, the elements in 245G.05 Subd. 2 can offer a helpful outline. (Note: consider completing a new assessment if obtaining previous assessment delays access to needed care.)
Provider completes an assessment or utilizes an existing assessment and would then create a DAANES assessment record for the individual. If using a previously completed assessment, it is the responsibility of the provider to review and update the severity ratings to determine if the level of care should remain the same as was previously indicated. Remember, the client chooses which level of service they wish to utilize that is equal to or less than what is recommended by the severity ratings. The client may also choose the service provider. This may be with the provider who did the assessment OR with another provider of their choice. Residential providers who do a comprehensive assessment for a client that chooses to go to, or is referred to, another facility for their care may bill for the comprehensive assessment done prior to admission into a program and done as a placing tool. If the client chooses treatment at your facility and begins treatment that same day, the comprehensive assessment is NOT payable separate from the daily per diem paid for the treatment services.
If the individual meets the appropriate severity ratings for the level of care your agency provides and chooses to attend your program, you can move forward with completing the DAANES admission record. If the client chooses or is referred to a different program, just complete the DAANES assessment record.
Counties/tribes may also choose to be enrolled with Minnesota Health Care Programs. As indicated in 254B.05 Subd. 1(c), “A county is an eligible vendor for a comprehensive assessment and assessment summary when provided by an individual who meets the staffing credentials of section 245G.11, subdivisions 1 and 5, and completed according to the requirements of section 245G.05. A county is an eligible vendor of treatment coordination services when provided by an individual who meets the staffing credentials of section 245G.11, subdivisions 1 and 7, and provided according to the requirements of section 245G.07, subdivision 1, paragraph (a), clause (5).”
Regarding the support of Minnesotans with SUD, a county’s main responsibility is an administrative one. Counties are required to determine an individual’s financial eligibility for the Behavioral Health Fund (Minnesota Administrative Rule 9530.7000 to 9530.7031). What this process looks like for each county/tribe may differ. Providers should contact the county/tribe to determine the process for establishing client’s eligibility for the Behavioral Health Fund. If the individual is eligible, then the county/tribe enters eligibility information into MN-ITS, either under an OO span or Medical Assistance; the provider may then view eligibility status of the individual in MN-ITS.
Counties and tribes are eligible to enroll with MHCP as indicated in 254B.05 Subd. 1(c), “A county is an eligible vendor for a comprehensive assessment and assessment summary when provided by an individual who meets the staffing credentials of section 245G.11, subdivisions 1 and 5, and completed according to the requirements of section 245G.05. A county is an eligible vendor of care coordination services when provided by an individual who meets the staffing credentials of section 245G.11, subdivisions 1 and 7, and provided according to the requirements of section 245G.07, subdivision 1, paragraph (a), clause (5).”
Counties help people access additional needed services for individuals with SUD, including food support, case management, medical services, detox, referral to SUD services, etc.
There is nothing that currently prohibits a county from billing treatment coordination while an individual is simultaneously in residential treatment. We encourage the county to work with the treating program to identify what type of treatment coordination the county is doing versus the program. The residential program is expected to be providing treatment coordination to the client according to licensing requirements. The county and residential provider would need to be able to work together to determine who is doing what in regards to the elements within treatment coordination as it is defined in 245G.07 (a) (5) so there isn’t duplication of efforts.
An individual who meets the staffing credentials of section 245G.11, subdivisions 1 and 7, and provided according to the requirements of section 245G.07, subdivision 1, paragraph (a), clause (5).”
As a Medicaid reimbursed service, the county must have sufficient documentation to justify the service provided and billed for as found in Minnesota Administrative Rule 9505.2175, Subp 1. For example, the county works with the client to determine how they can best assist them and document this in a plan. Then the county document efforts and interactions that are billed for that should be connected to one of the treatment coordination services in 245G.07, subdivision 1 (a)(5).
Direct Access allows for the individual to complete a comprehensive assessment and choose the provider and level of care they would like to participate in, up to the highest level of care determined necessary. i.e., An individual may be assessed for residential level of care. Still, due to a number of circumstances, they are only willing to participate in nonresidential care. This choice is an example of downward deviation occurring.
It is important that providers assist those seeking treatment in understanding that there are different levels of care options and the risks and benefits that could result from choosing each level of care. Additionally, assisting individuals in understanding the variety treatment providers and program options is vital. We hope that no matter the level of care recommendation, individuals are aware of their choices both in the level of care and in the treatment provider/program. At this time, there is no specific form or notification developed to inform clients of their choice. This DHS webpage offers help and direction to services such as Fast Tracker and other resources to help identify treatment providers and level of care options.
DHS would encourage the criminal justice system to support client choice; however, DHS does not have oversight or the ability to dictate the role of a judge. The court has the authority to require the individual to follow the recommendations of the comprehensive assessment. The counselor completing the assessment does not have the authority to require an individual to follow the recommendation. The client has the choice to negotiate with the court if they cannot/or do not want to follow the recommendations of a comprehensive assessment, meaning that it is a conversation between court/court-appointed representatives (probation/parole officers) and the individual versus the counselor completing the assessment and the individual. While DHS is taking the following steps to educate the criminal justice system on direct access, it should be noted continued education from SUD providers to criminal justice system personnel is encouraged as Direct Access becomes the new norm.
It may be helpful to provide clear documentation as to what the counselor recommends based on severity ratings and the client’s choice of treatment in which they would like to participate. In circumstances where the client chooses a lower level of care than the counselor recommends, the severity ratings do not change to fit the client’s choice. Instead, the severity ratings stay consistent with the counselor’s recommendation of the level of care.
The comprehensive assessment requires a mental health screening with a tool approved by the Commissioner (245G.05 Subd. 1 (8)). The Global Appraisal of Individual Needs Short Screening (GAIN-SS) is intended to quickly and accurately identify clients who would be flagged as having one or more behavioral health disorders, suggesting the need for a referral to some part of the behavioral health treatment system. The GAIN-SS has four screener domains, two of these domains are used to meet the requirements of a mental health screen: Internalizing Disorders (IDScr) and Externalizing Disorders (EDScr). According to the GAIN-SS manual (2013), a score of 1-2 (moderate) on each of the sub screeners is considered a positive mental health screen. A moderate score indicates “A possible diagnosis and possibly in need of services; the client is likely to benefit from a brief assessment and brief intervention.” A score of 3 or higher indicates “High Probabilities of a diagnosis and need for services; the client is likely to need more formal assessment and intervention, either directly or through referral.”
The comprehensive assessment does not have specific timelines (outside of licensing requirements) in regards to when an update needs to be completed or how long a comprehensive assessment can last. Whenever admitting an individual to services, it is the responsibility of the provider to review the most current comprehensive assessment and update necessary information. There will be a number of historical pieces that will not have changed, but there needs to be enough current information to justify the level of care being received based on the client’s severity ratings. This highlights the goal of balancing the person-centered concept of avoiding having the client repeat their history and circumstances numerous times due to repetitive assessments, along with the need to update what has occurred in the client’s life since the last assessment to determine current needs, severity ratings and appropriate level of care.
A provider completing a comprehensive assessment must ALWAYS input that information into the DAANES assessment tab, whether or not the individual will be receiving services from you, and regardless of funding stream. For public pay clients, the completion of the DAANES assessment record is required in order to be eligible for reimbursement.
For individuals funded through the Behavioral Health Fund (BHF), current risk ratings will need to be added to the DAANES assessment record when BHF eligibility span ends (also referred to as the “OO span” in billing) and a new one begins.
A residential provider can bill for the comprehensive assessment that they do for a client who is referred to another facility or enters treatment with them on a different day than the comprehensive assessment was done. If the assessment is done on the same day as the client begins residential treatment, and by the same provider, then it is included in the per diem rate for that residential provider. If the comprehensive assessment is done as a tool to refer the client to appropriate services at a different facility, and its done prior to admission into a program, residential providers can bill for it. (NOTE: In order to bill for the comprehensive assessment, the provider must be enrolled with MHCP.)
Both the Substance Abuse Mental Health Services Administration (SAMHSA) and Centers for Medicare and Medicaid Services (CMS), federal funders of the Behavioral Health Fund, continue to focus on timely access to treatment and state responsibility to manage access and client wait times. In addition, through the receipt of the Federal Block Grant, Minnesota is required to assure that pregnant women, pregnant injecting women, and drug injecting users are given priority access to services. If your agency is not able to provide an assessment in a timely manner or there is a waitlist, additional resources for other providers shcould be given to the individual seeking an assessment.
Licensed SUD treatment programs must admit the client and follow all licensing standards, including timelines and paperwork, in order to provide any treatment services.
After the completion of a comprehensive assessment, counties and tribes may begin billing for treatment coordination (as long as they are enrolled with Minnesota Health Care Programs to bill for the service). Counties and Tribes not enrolled to provide formal outpatient treatment do not complete DAANES admission records at this time, only the DAANES assessment records.
Although there are portions of SBIRT and the associated services that this may authorize included in statute, this has not yet been implemented. Until this process has been fully implemented in 2023, the above responses apply.
A licensed professional in private practice is an eligible vendor identified in 254B.05, subdivision 1. This section of the statute identifies the services this individual is eligible to provide. There is a definition of a licensed professional in private practice is located in 245G.01, subdivision 17, which does not allow for multiple licensed professionals to affiliate to provide alcohol and drug counseling. If you are unsure whether or not you need a 245G program license, please contact DHS licensing.
Licensed professionals in private practice are not licensed by DHS, rather, they are held to the standards of their applicable governing licensing board. It is the provider’s responsibility to be well versed in these rules and regulations and reach out to their board if they have questions.
Licensed professionals in private practice need to be enrolled with Minnesota Health Care Programs in order to bill for services. See 254B.05 subdivision 1 (b) for details of what qualifies an individual to enroll and what services they are eligible to provide, licensed professional in private practice are not eligible to provide peer recovery support services.
Licensed professionals in private practice must complete DAANES and document accordingly. For more information on enrollment for SUD services, you can refer to the SUD Services Enrollment Criteria and Forms page.
Eligible providers for SUD can be found in 254B.05. Please review the Minnesota Health Care Programs Substance User Disorder Services Enrollment Criteria and Forms page. It is also important for you to be aware of the Substance Use Disorder provider manual page. Please reach out to the Provider Resource Center at 651-431-2700 with additional enrollment questions.
Please refer to the Substance Use Disorder (SUD) Services section of the Minnesota Health Care Programs (MHCP) Provider Manual for billing policy. For questions about fee-for-service coverage policies and billing procedures provided to MHCP members, contact the Provider Resource Center at 651-431-2700 or 800-366-5411. Communication regarding billing may not always come through a Behavioral Health e-memo as our division works primarily on policy, so please keep an eye on MHCP provider news and updates webpage and your MN–ITS mailbox.
We recommend that all counties and tribes use Behavioral Health Fund Request (PDF) to be consistent across the state. We also recommend that even after the client is determined as eligible for the behavioral health fund, the provider assist the client in getting access to medical assistance, which will help provide better overall access to care for the client.
The Behavioral Health Fund (BHF) (PDF) is available for clients seeking SUD services in jails, even if Medicaid is not an option. Counties must establish financial eligibility.
All eligible vendors of substance use disorder services need to complete DAANES. There are four different DAANES records that need to be completed: assessment, admission, six-month Review (opioid replacement therapy clients only), and Discharge. The data entry into DAANES can be done by any staff who has access. This is a decision that your facility makes regarding workflow.
DAANES has 4 different record types: assessment, admission, six-month update (opioid treatment program only), and discharge. The type of service you are enrolled to provide determines which records you will complete.
The assessment record is completed by all enrolled substance use disorder providers including counties, tribes and Recovery Community Organizations. For publicly-funded clients with an eligibility span, a completed assessment DAANES creates a billing span for the date of assessment, and a six-month span for treatment coordination and peer support if you are able to bill for these services.
The admission record is completed by eligible vendors who are enrolled to provide residential and/or nonresidential treatment services. Within the admission record, eligible vendors are able to create treatment service records for the Direct Access OO-covered clients using the Behavioral Health Fund.
The discharge record is completed by all providers who have entered an admission record.
The six month update record is completed at 6 months intervals by Opioid Treatment Programs
DAANES connects to the billing system using the client’s PMI and coverage type selected. The claims systems processing is dependent and determined based on the coverage type selected within the DAANES admission.
If an updated assessment record is required due to establishing a new financial eligibility span for a client, a substance use disorder treatment provider may use the severity ratings and assessment date from the most current treatment plan review. If an updated assessment record is required for a county/tribe or Recovery Community Organization, they would need to have a qualified individual determine current severity ratings by doing a comprehensive assessment update and have this documented in their records.
Contact the DAANES support desk (dhs.daanes@state.mn.us) and request a user registration form. It will be emailed to you. You fill that out and return to either the fax on the form or to the email you received it from. Make sure to fill the form in completely.
Please email dhs.daanes@state.mn.us and they will be sent to you.
