Direct Access: Frequently Asked Questions

1. Determine coverage

   The first step is to determine if the client has insurance. Ask the client and verify eligibility in MN–ITS. You can continue with the Direct Access process immediately if there is either Medical Assistance or OO eligibility in MN–ITS.
   
   
   • For those enrolled with a Managed Care Organization (MCO), the provider should coordinate the treatment and payment with the plan. Call the MCO for further instruction.
   • If the client does not have eligibility indicated in MN–ITS, connect with the individual’s county/Tribe of financial responsibility to determine if they may be eligible for funding through the Behavioral Health Fund (BHF). Although the financial eligibility guidelines are the same, please coordinate with the county/Tribe to complete financial eligibility determination.
   • If the client has Medical Assistance or OO eligibility and commercial insurance, the provider must contact the county/Tribe of residence and ask them to enter the insurance information into the Third-Party Liability File. The provider must bill the insurance first and bill the rest to DHS to be paid by the Behavioral Health Fund.
   • A list of contact information for counties can be found in the “Guide to Minnesota’s Public Health Care Programs.” 

2. Client choice

   Client choice in Minnesota's Direct Access system means that individuals needing help with substance use disorder can pick the treatment provider they want to work with. A referral from a county or tribe to choose a provider is not required. This allows the individual to find a treatment program that feels right for them and get the individualized care they need more quickly.

3. Access previous assessment

   If the client wants to continue to follow Direct Access process and is financially eligible, 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 assessment. Review and update the assessment to determine current severity ratings.

4. Completing an assessment

   The provider completes an assessment or utilizes an existing assessment and then creates a DAANES assessment record for the individual. It is the responsibility of the provider, if using a previously completed assessment, 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 care they wish to utilize that is equal to or less than that which 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.

5. Admit and provide service or refer to appropriate level of care.
   
   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).”

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.

Counties and Tribes have continued responsibility for determining an individual’s financial eligibility for the Behavioral Health Fund. What this process looks like for each county or Tribe may differ. Please reach out to the county/Tribe to determine what their process is for determining client’s eligibility for the Behavioral Health Fund. If it is determined the individual is eligible, it is the responsibility of the county/Tribe to do the system work necessary to allow a provider to be able to verify eligibility in MN–ITS and see major program OO or Medical Assistance.

An individual who meets the staffing credentials of section 245G.11, subdivisions 1 and 7, and provides coordination according to the requirements of section 245G.07, subdivision 1, paragraph (a), clause (5).”

Direct Access allows for an individual to choose where they would like to access treatment by removing Rule 25 placing authority and the MMIS Service Agreement which dictates the provider and units authorized by the placing authority. Individuals will be able to seek out the provider of their choice. In the Direct Access process there is no service agreement with a specified level of care and treatment location that the individual must follow. This process will allow for the individual to have a comprehensive assessment completed and then choose the provider and level of care they would like to participate in; up to the highest level of care determined necessary. For example, an individual may be assessed for residential level of care, but due to several circumstances they are only willing to participate in nonresidential care.

DHS would encourage that the criminal justice system 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 client has the choice to negotiate with the court if they cannot/or do not want to follow the recommendations of a comprehensive assessment.

Licensed SUD treatment programs must admit the client and follow all licensing standards, including timelines and paperwork, to provide any treatment services.

Although licensed professionals in private practice are not held to all the same standards as SUD licensed programs, if the properly MHCP enrolled provider plans to provide treatment services for the individual, they should complete a DAANES admission record and document accordingly. Please also note, as indicated in 254B.05, licensed professionals in private practice are not eligible to provide peer recovery support services.

Counties and tribes may bill for treatment coordination (as long as they are enrolled with Minnesota Health Care Programs to bill for the service) after the completion of a comprehensive assessment. Counties and Tribes not enrolled to provide formal outpatient treatment do not complete DAANES admission records at this time, only assessment records.

When an SBIRT is conducted and an individual screens positively for a substance use disorder they are eligible to receive a set of services prior to the completion of a comprehensive assessment (254A.03, Subdivision 3 (c)). If a licensed SUD treatment program is providing the SBIRT approved services, the individual must still be admitted to the program, but certain paperwork is exempt (245G.02, Subdivision 2).

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 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 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 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. For more information on enrollment for SUD services, you can refer to the SUD Services Enrollment Criteria and Forms page.

The comprehensive assessment for substance use disorder treatment is a detailed evaluation by a qualified professional to diagnose the substance use disorder, screen for co-occurring mental health issues, assess risks and recommend appropriate levels of care.

There is no single, Commissioner approved or mandated “tool” or form for a comprehensive assessment. There are elements that are required to be included in the comprehensive assessment and summary and this can be found in 245G.05.

The comprehensive assessment requires a mental health screening with a tool approved by the Commissioner (245G.05 Subd. 3 (2)). Currently the entirety of the GAIN-SS must be completed and maintained in the client record. If the individual has a total score of 1 or more in the IDScr section, the screen would be considered a positive mental health screen. According to the GAIN-SS manual (2005), a score of 1-2 indicates a “Moderate (1 to 2) Possible Diagnosis; the client is likely to benefit from a brief assessment and nonresidential intervention.”

The comprehensive assessment does not have specific timelines (outside of licensing requirements) in regard 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 several 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 the individual will be receiving services from you or not and regardless of funding stream. 

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 it’s done prior to admission into a program, residential providers can bill for it.

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 could be given to the individual seeking an assessment.

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 Call 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 Call 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.

Counties and tribes use the Behavioral Health Fund Request form in determining a client's eligibility for BHF. The individual seeking funds for services must complete this form. The provider may assist the individual in completing the form. The form must include complete and accurate information and be signed by the individual seeking funds for services. 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) is available for clients seeking SUD services in jails, even if Medicaid is not an option. Counties must establish financial eligibility (Rule 24).

All eligible vendors of substance use disorder services need to complete DAANES. Depending on the type of provider, there are different DAANES records that need to be completed. For licensed SUD providers, all comprehensive assessments and every episode of treatment needs to be entered into DAANES. For Counties/Tribes (those not also licensed as SUD treatment providers) and Recovery Community Organizations, only the DAANES assessment needs to be completed to begin to provide any services. 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 five different record types: assessment, admission, six-month update (Opioid Treatment Program only), treatment service 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. 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 can create treatment service records for the Direct Access 00 covered clients using the Behavioral Health Fund and no service agreement. The discharge record is completed by all providers who have entered an admission record. The six-month update record is completed at six months intervals by Opioid Treatment Programs.

Contact the DAANES support desk (dhs.daanes@state.mn.us) and request a user registration form. It will be emailed to you. Complete the form and return to either the fax number 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.