Below are some questions and answers about the Department of Public Health’s Integration Initiative for licensure of programs providing integrated outpatient primary care, mental health and substance abuse services. Check back for additions to these FAQs.
- What is the purpose of the DPH Integration Initiative?
- What providers are eligible to participate in the Integration Initiative?
- What is the role of the Integration Initiative Committee (IIC) in the licensure process?
- What DPH licensure requirements apply to outpatient providers seeking to offer integrated services?
- What is the licensure process for an outpatient provider proposing to offer integrated services?
- What happens after the IIC has reviewed the proposal?
A. The purpose of the Integration Initiative is to streamline the licensure process for outpatient providers seeking to offer integrated primary and behavioral health care services to their patients. The provision of integrated primary and behavioral health care services is central to the Commonwealth’s health care reform agenda.
A. Any provider proposing to offer at least 2 of the following 3 outpatient services to patients at their program location are eligible to participate in the Integration Initiative: primary medical care, mental health care, and substance abuse services.
Eligible providers include (1) those seeking new licensure from the Department; (2) clinics currently licensed by the Division of Health Care Quality (DHCQ); and (3) substance abuse treatment programs currently licensed by the Bureau of Substance Abuse Services (BSAS).
A. Outpatient providers proposing to offer integrated primary care and behavioral health services are required by state law to be licensed by DPH. (M.G.L. c. 111B, §§6 & 6A; c.111E, §7; and c.111, §51) In most cases, the provider will need a clinic license from DHCQ and must comply the clinic licensure regulation at 105 CMR 140.000.
The role of the IIC is to streamline the licensure process by helping providers to achieve their goals for integration while complying with state and federal law requirements that ensure quality care. The IIC is composed of staff in the Commissioner’s office, DHCQ, BSAS and the Office of General Counsel who will work collaboratively with providers to identify and resolve perceived or real licensure barriers to integration.
A. In most cases, the provider will need a clinic license from DHCQ and must comply the clinic licensure regulation at 105 CMR 140.000. For example, an existing DHCQ-licensed primary care clinic that proposes to add mental health services must apply for an amended clinic license and comply with the mental health services section of the regulation, 105 CMR 140.500-560. And a primary care clinic that proposes to add substance abuse treatment services must apply for an amended clinic license and comply with the programmatic and staffing requirements of the substance abuse treatment program regulation, 105 CMR 164.000.
In most cases, a free-standing substance abuse treatment program licensed by BSAS that proposes to add primary care or mental health services for its clients will apply for a DHCQ clinic license and must comply with applicable requirements of the clinic licensure regulation, 105 CMR 140.000.
A. In order to add integrated services, a BSAS-licensed treatment program or DHCQ-licensed clinic will apply for licensure to add new services. A new provider must apply for a new license. The first step is to review the clinic (105 CMR 140.000) and substance abuse treatment program (105 CMR 164.000) licensure regulations if the applicant is not already familiar with them. Then the applicant will complete and submit an “Intent to Integrate” form for review by the IIC [insert link to form]. The IIC will review the form and contact the applicant to discuss the proposal.
A. The IIC will work with the applicant to develop an integration proposal that meets licensure requirements, and will recommend the best path to licensure. In appropriate circumstances, the IIC may recommend that the Commissioner waive or modify some licensure requirements to facilitate integration. In most cases, the applicant will follow the DHCQ-clinic licensure process, with assistance from the IIC as needed.