DHS outlines guidance for the appropriate use of AMHI grant funds for uncompensated mental health services

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Behavioral Health e-Memo

#25-35

12/9/25

DHS outlines guidance for the appropriate use of AMHI grant funds for uncompensated mental health services

DHS is offering guidance for the appropriate use of Adult Mental Health Initiative (AMHI) grant funds to support uncompensated mental health services for adults with serious and persistent mental illness (SPMI). AMHI initiatives are responsible for developing and maintaining a comprehensive adult mental health service continuum, including ensuring access for individuals who lack insurance coverage for essential behavioral health services.

Use of AMHI Funds for Direct Services

AMHI/CSP funds may be used to provide direct mental health services—as defined in Minnesota Statute 245.4661, subdivision 9—for individuals who:

  • Have a diagnosed SPMI, and
  • Do not have insurance, or
  • Have insurance that does not cover the needed behavioral health services

Direct services under subdivision 9 must meet DHS standards for medical necessity, provider qualifications and documentation.

1. Coordinated and Priority Use of All Available Funding Sources

AMHI funds operate within a broad behavioral health financing system:

  • First, utilize all available payer sources (e.g., MA/Medicaid, county funds, private insurance, federal block grant funds).
  • Coordinate across funding streams to support smooth access to care.
  • AMHI funds may be used when no other reimbursement option exists or when a necessary service is not covered.
  • Counties have the discretion to evaluate individual situations and determine whether AMHI funds may be used, in accordance with state-established parameters.
  • The purpose is to fill gaps in service delivery—not to replace existing payers.

This approach preserves AMHI funds for individuals who would otherwise face barriers to needed care.

2. Coverage of Uncompensated or Uncovered Costs

This use is intended to ensure individuals can receive medically necessary care without interruption due to lack of coverage.

AMHI funds may be used to support uncompensated or uncovered mental health service costs when:

  • The service falls within the scope of Minn. Stat. 245.4661, subd. 9, and
  • No other payer is available to cover the service

For provider reference, “uncompensated care” generally means situations where a needed service cannot be billed to insurance or another payer, such as:

  • Services that are excluded, denied or not reimbursable under an individual’s insurance plan
  • Lack of active insurance coverage
  • Individuals who qualify for SPMI services but have limited commercial insurance that does not include mental health benefits
  • Insurance limits or caps that have been reached (e.g., session limits, non-covered service categories)

These examples are intended to guide interpretation—not restrict flexibility—and help providers identify when AMHI funding may be an appropriate resource.

3. Standards for Invoicing and Documentation

To ensure consistency and accountability:

  • Invoiced services must align with DHS requirements for individual mental health service reimbursement, including the use of appropriate BRASS codes
  • Counties and providers should collaborate to ensure accurate billing, supporting documentation and reporting

Counties and providers share responsibility for ensuring AMHI funds are used effectively and within state parameters. When applied appropriately, AMHI resources help ensure that Minnesotans with SPMI receive essential, direct mental health services when other funding sources are not available. Funding decisions should reflect individual need, funding availability and adherence to state guidance on allowable expenditures.


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For more information about this e-memo please feel free to contact us at youropinionmatters.dhs@state.mn.us.