Clarification of roles and abilities of counties providing SUD treatment coordination

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Behavioral Health e-Memo

#22-32

10/26/2022

Clarification of roles and abilities of counties providing SUD treatment coordination


In response to inquiries about counties’ roles and options in SUD treatment, the Behavioral Health Division (BHD) is providing this summary of three key areas of interest for counties. Specifically, the following answers provide clarity around care coordination/treatment coordination for counties without 245G substance use disorder treatment licensing and who are enrolled with Minnesota Health Care Programs (MHCP).

Who can provide treatment coordination?

Counties can bill for care (treatment) coordination when they are enrolled with Minnesota Health Care Programs, have staff who meet the qualifications of treatment coordinator (245G.11, subdivisions 1 and 7) and when the services are provided according to 245G.07, subdivision 1, (a)(5).  

What is the scope of work and what are the documentation requirements?

Minnesota Statute 245G states that treatment coordination (referred to as “care coordination” in 254B.05) must be done one-to-one, may include facilitation of referrals, assists with coordination with others involved in the individual’s care, responds to needs identified on the comprehensive assessment or treatment plan and more (MS 245G.07, subdivision 1 (a)(5)). Unlike SUD “treatment programs,” which require any treatment service to be provided according to a client’s treatment plan, counties are only required by statute to provide “treatment coordination” services. However, as this is a Medicaid reimbursed service, documentation is required both to justify the service and billing for the service provided, per Minnesota Administrative Rule 9505.2175, subpart 1.

What is county service coordination for county versus program?

When the client is receiving services from a 245G program, the county’s coordination efforts can be referenced in the treatment plan at the program, as well as in the county provider’s records. However, if the client is not receiving services in a 245G program, the county must have both sufficient documentation for rationale, as well as elements of treatment coordination provided (245G.07, subdivision 1(a)(5)).

It is the policy of the Behavioral Health Division that a county properly enrolled in MHCP may provide treatment coordination under a care plan the county has created, by a treatment coordinator meeting the requirements of 245G.11, subdivision 7.

If you have any questions about this e-memo, please feel free to contact SUD.Direct.Access.DHS@state.mn.us.


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