Massachusetts - Housing Stabilization — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

MassHealth funds housing search, landlord mediation, and tenancy retention through the Community Support Program for Homeless Individuals (CSP-HI) and the Tenancy Preservation Program (CSP-TPP) under the state's Section 1115 Demonstration Waiver. Providers must first secure a mental health or substance use disorder clinic license from the Massachusetts Department of Public Health (DPH) before submitting a MassHealth enrollment application under 130 CMR 461.000.

Approval requires demonstrating clinical supervision capacity, trauma-informed care protocols, and direct contracting with MassHealth Accountable Care Organizations (ACOs) and the Massachusetts Behavioral Health Partnership (MBHP). Standalone housing agencies cannot bill MassHealth directly for these services unless they establish a DPH-licensed behavioral health clinic or subcontract under an existing licensed CSP provider.

1. Service Definition and Scope

CSP-HI and CSP-TPP deliver pre-tenancy and tenancy-sustaining supports to MassHealth members experiencing chronic homelessness or facing imminent eviction. Services include housing search, application assistance, landlord mediation, benefit coordination, and eviction prevention.

These services are delivered primarily in the community, at shelters, or in the member's home, rather than in a facility-based clinic setting, though the provider must maintain a licensed clinic base of operations.

• Pre-Tenancy Support: Assisting members with housing applications, obtaining identification documents, and securing move-in funds.
• Tenancy Sustaining: Mediating landlord disputes, providing lease compliance education, and connecting members to community resources.
• Target Population (CSP-HI): Chronically homeless individuals defined by federal and state criteria.
• Target Population (CSP-TPP): Individuals facing eviction due to behavioral health conditions.
• Service Setting: Delivered in the community, shelters, or the member's home.

2. Regulatory and Oversight Agencies

The Executive Office of Health and Human Services (EOHHS) administers MassHealth and sets the overarching policy and rates for CSP services. The Department of Public Health (DPH) issues the prerequisite facility licenses required to operate.

Because CSP is primarily a managed care benefit, the Massachusetts Behavioral Health Partnership (MBHP) and various Accountable Care Organizations (ACOs) handle network credentialing and authorization.

• Executive Office of Health and Human Services (EOHHS): Administers the MassHealth 1115 Waiver and sets CSP rates (https://www.mass.gov/orgs/executive-office-of-health-and-human-services).
• Department of Public Health (DPH): Licenses the underlying mental health and SUD clinics required for CSP enrollment (https://www.mass.gov/orgs/department-of-public-health).
• MassHealth Provider Online Service Center (POSC): Processes the Medicaid enrollment applications (https://newmmis-portal.ehs.state.ma.us/EHSProviderPortal).
• Massachusetts Behavioral Health Partnership (MBHP): Manages the behavioral health network and credentials CSP providers (https://www.masspartnership.com).

3. Gatekeeping Prerequisites: Who Can Even Apply

MassHealth does not enroll standalone housing or social service agencies as CSP providers. An applicant must already operate as a licensed behavioral health entity.

Providers must secure managed care contracts to receive referrals and payment, as fee-for-service MassHealth covers only a small fraction of the eligible population.

• DPH Licensure Prerequisite: Applicant must hold a valid license issued by DPH to provide mental health or substance use disorder services (130 CMR 461.404(A)).
• Managed Care Contracting: Providers must secure contracts with MassHealth ACOs, MCOs, or MBHP to receive referrals and payment.
• Satellite Location Restrictions: Enrollment is location-specific; any additional satellite CSP program must reapply for separate enrollment (130 CMR 461.404(C)).
• Clinical Standards Compliance: Must submit written documentation proving the agency meets EOHHS clinical standards for specialized CSP services.

4. Licensure and Certification Requirements

Because CSP is a behavioral health service, the agency must meet DPH clinic licensure standards under 105 CMR 140.000 (Licensure of Clinics) or 105 CMR 164.000 (Substance Abuse Services).

This requires passing an architectural review for the physical clinic space and submitting comprehensive clinical policy manuals.

• Clinic License: Issued by DPH Bureau of Health Care Safety and Quality (BHCSQ) for mental health clinics.
• Architectural Review: DPH requires physical plant approval for the clinic base of operations.
• Policies and Procedures: Must submit manuals covering trauma-informed care, safety protocols, and accessibility (130 CMR 461.405).
• Two-Year Cycle: DPH licenses are typically renewed every two years following a successful compliance survey.

5. Medicaid Provider Enrollment

After obtaining DPH licensure, the agency applies through the MassHealth POSC. The application requires specific attachments proving CSP capability.

Providers must explicitly apply for the CSP-HI or CSP-TPP specialty designation during the enrollment process to bill for housing-specific codes.

• System: MassHealth Provider Online Service Center (POSC).
• Provider Type: Enrolled under the Community Support Program (CSP) provider type.
• Required Form: MassHealth Data Collection Form (DCF) and the Federally Required Disclosures Form (FRDF).
• Specialized Designation: Must explicitly apply for the CSP-HI or CSP-TPP specialty designation.

6. Staffing, Training and Background Checks

CSP relies on unlicensed community health workers, peer specialists, and bachelor's-level staff, but requires strict clinical supervision by licensed professionals.

All staff conducting community visits must pass background checks and complete state-mandated training modules.

• Clinical Supervisor: Must be a licensed mental health professional (e.g., LICSW, LMHC) in good standing with their Massachusetts board.
• Direct Care Staff: Often bachelor's degree holders or individuals with lived experience in homelessness or recovery.
• Background Checks: Criminal Offender Record Information (CORI) checks are mandatory for all staff.
• Training Requirements: Staff must complete training on trauma-informed care, traumatic brain injuries, and safety protocols (130 CMR 461.405(B)).

7. Documentation, Policies and Records

MassHealth requires comprehensive member records that justify the medical necessity of housing stabilization as a behavioral health intervention.

Agencies must maintain a written staffing plan and strict conflict of interest policies, particularly if the agency also owns or manages housing.

• Member Record: Must include demographics, place of service, precipitating events, and written documentation meeting EOHHS clinical standards (130 CMR 461.406).
• Staffing Plan: Must maintain a written plan ensuring all supervision requirements are met (130 CMR 461.405(D)).
• Conflict of Interest Policy: Must have a policy preventing self-dealing between service provision and housing management.
• Incident Reporting: Must follow DPH and MassHealth protocols for reporting adverse events in the community.

8. Billing, Rates and Claims

CSP services are billed in 15-minute increments. Rates are established by EOHHS under 101 CMR 446.00 or related behavioral health rate regulations.

Claims are submitted electronically to the POSC or the respective managed care plan's clearinghouse.

• Procedure Code: Typically billed using H2016 (Comprehensive Community Support Services) with specific modifiers for HI or TPP.
• Unit of Service: Billed in 15-minute increments for direct face-to-face or telehealth contact.
• Rate Setting: EOHHS sets the maximum allowable fees; actual rates may vary slightly based on ACO/MCO contracts.
• Claim System: Claims are submitted via 837P electronic transactions.

9. Approval Sequence and Timeline

The critical path runs through DPH licensure first, which is the longest phase, followed by MassHealth enrollment and managed care credentialing.

Providers should expect the entire process from entity formation to billable status to take over a year.

• Phase 1: Entity formation and DPH architectural/policy review (6-9 months).
• Phase 2: DPH initial licensure survey and license issuance (2-3 months).
• Phase 3: MassHealth POSC enrollment application processing (60-90 days).
• Phase 4: MBHP and ACO network credentialing and contracting (90-120 days).

10. Common Denials and Survey Findings

Applications and surveys frequently fail when agencies treat CSP as a standalone housing service rather than a clinically supervised behavioral health program.

Reviewers strictly enforce the separation of locations and the presence of licensed clinical supervisors.

• Missing Prerequisite: Applying to MassHealth without the required DPH mental health or SUD clinic license.
• Inadequate Supervision: Failing to document the required ratio of licensed clinical supervisors to unlicensed CSP workers.
• Location Errors: Attempting to bill for services at an unapproved satellite location (130 CMR 461.404(C)).
• Documentation Deficiencies: Member records lacking the specific clinical justification for CSP-HI or CSP-TPP eligibility.

11. Key Contacts and Resources

Providers must navigate resources from EOHHS, DPH, and the managed care entities to maintain compliance.

The MassHealth provider manuals and DPH licensure regulations are the primary source documents for ongoing operations.

• MassHealth Provider Enrollment: Customer service for POSC applications (https://www.mass.gov/masshealth-provider-enrollment-and-credentialing).
• DPH Bureau of Health Care Safety and Quality: For clinic licensure inquiries (https://www.mass.gov/orgs/bureau-of-health-care-safety-and-quality).
• Massachusetts Behavioral Health Partnership (MBHP): For network contracting and CSP clinical guidelines (https://www.masspartnership.com).
• MassHealth Provider Regulations: 130 CMR 461.000 Community Support Program Services (https://www.mass.gov/doc/community-support-program-services/download).

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