Q

1. Do we need to request licensing as well if our Coordinating Agency has already established case management services? 

A

Yes.

Q

2. Will there be any license or category for counseling required for buprenorphine and other chemotherapies? Under which category will this be provided?

A

THE SHORT ANSWER IS "NO."  HOWEVER, ANY LICENSURE SHOULD REFLECT THE SETTING AND, IF APPROPRIATE, THE SERVICE CATEGORY.  EXAMPLES INCLUDE:

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RESIDENTIAL SUB-ACUTE DETOXIFICATION LICENSURE IS REQUIRED IF BUPRENORPHINE IS BEING PROVIDED WITHIN A RESIDENTIAL SUB-ACUTE DETOXIFICATION PROGRAM. 

PHYSICIANS APPROVED BY THE Drug Enforcement Agency (DEA) AS BUPRENORPHINE PRESCRIBERS DO NOT REQUIRE SUBSTANCE ABUSE LICENSURE. 

SUBSTANCE ABUSE LICENSURE IS REQUIRED IF THE PHYSICIAN IS PROVIDING COUNSELING AND ACCEPTS PAYMENT FOR TREATMENT, REHABILITATION OR PREVENTION OF SUBSTANCE ABUSE.

Q

3. We have an outpatient treatment license.  We always did co-occurring integrated treatment.  Now that this is recognized, do we need the integrated treatment license? 

A

YES.

Q

4. There has been talk about merger of substance abuse and mental health.  If this happens, will all mental health organizations need an organizational license? 

A

A SUBSTANCE ABUSE TREATMENT OR PREVENTION LICENSE IS REQUIRED FOR ANY ORGANIZATION OFFERING OR PURPORTING TO OFFER SUBSTANCE ABUSE TREATMENT, REHABILITATION OR PREVENTION. 

Q

5. Case management has other models--such as rehabilitation evidence based practice?  If case management is provided within another evidence based practice such as rehabilitation, is licensure required? 

A

CASE MANAGEMENT IS A NEW SERVICE CATEGORY AND ALSO REQUIRES LICENSURE AS AN OUTPATIENT, RESIDENTIAL OR METHADONE CLINIC PROGRAM.

Q

6. Do the Coordinating Agencies review licensed programs who want to add the new categories? 

A

YES.

Q

7. Can a mental health agency contract with a substance abuse services provider for integrated treatment and vice-versa?

A

ANY PROVIDER OF SUBSTANCE ABUSE SERVICES MUST BE APPROPRIATELY LICENSED REGARDLESS OF THEIR PROVIDER NETWORK PARTICIPATION.

Q

8. Existing mental health agency is applying for substance abuse license.  How soon do individual staff/supervisor need to be certified addictions counselor qualified?

A

STAFF QUALIFICATIONS ARE NOT ADDRESSED IN THE SUBSTANCE ABUSE ADMINISTRATIVE RULES.  THESE ARE SUBJECT TO THE REQUIREMENTS OF THE CONTRACTOR.

Q

9. Are assertive community treatment programs required to be licensed if it offers or purports to offer substance abuse services on the team?

A

YES.

Q

10. Can a program that currently has a Screening, Assessment, Referral & Follow-up (SARF) license obtain a case management or other new licensing category?

A

A SUBSTANCE ABUSE PROGRAM CURRENTLY LICENSED ONLY AS A SARF CANNOT OBTAIN LICENSURE UNDER ONE OF THE NEW LICENSING CATEGORIES.

Q

11. Is there a fee for licensure?

A

NO.

Q

12. Does licensure require any specific degrees, licenses, or certifications?

A

NO.

Q

13. What does an agency need to do to become licensed for one of these new service categories?

A

AGENCIES THAT WOULD LIKE TO BECOME LICENSED FOR ONE OF THE NEW SERVICE CATEGORIES NEED TO COMPLETE THE LICENSE CHANGE OF INFORMATION FORM (BHS-L&C-601).   AGENCIES MUST COMPLETE AND MAIL AN Application for a Substance Abuse License FORM (BHS-LC-106) IF NOT CURRENTLY LICENSED.  THESE FORMS ARE AVAILABLE BY CLICKING ON THE FORM NAME ABOVE OR GOING TO THE BUREAU OF HEALTH SYSTEMS' WEBSITE (http://www.michigan.gov/bhs).

Q

14. The License Change of Information form asks for "documentation of how your program conforms to the definitions relevant to each category."  Is there any more specific guidance?

A

THERE CANNOT BE ANY MORE SPECIFIC GUIDANCE SINCE THERE ARE NO PROTOCOLS OUTSIDE OF THE DEFINITIONS THEMSELVES IN THE RULES.  PROGRAMS SHOULD EITHER DOCUMENT WHAT THEY ARE CURRENTLY DOING OR WHAT THEY PROPOSE TO DO.  DESCRIPTIONS ARE MOST USEFUL WHEN BRIEF AND TO THE POINT. 

Q

15. If my agency gets a license, is there any associated funding? 

A

NO.  LICENSURE IS DISTINCT FROM FUNDING.  HOWEVER, LICENSURE PERMITS THE AGENCY TO OFFER THE SERVICE AND WOULD BE REQUIRED BY THE FUNDING AGENT. 

Q

16. Do recipient rights and substance abuse-related confidentiality requirements apply to these new services? 

A

YES.