Minnesota - Behavioral Health Services — Licensing, Medicaid Enrollment and Startup Requirements

Last reviewed: 2026-09-10

Minnesota Department of Human Services (DHS) licenses behavioral health and positive support services under Minnesota Statutes, Chapter 245I for mental health clinics and Chapter 245D for Home and Community-Based Services (HCBS) waiver providers. These services, which include assessment, therapy, positive behavior support, and crisis response, are funded through Medical Assistance (MA) and waivers such as the Brain Injury (BI), Community Access for Disability Inclusion (CADI), and Developmental Disabilities (DD) waivers.

Before submitting an enrollment application through the Minnesota Provider Screening and Enrollment (MPSE) portal, an applicant must secure the underlying 245I or 245D license and obtain a DHS-approved service authorization (SA) from a lead agency. Providers cannot bill or receive payment from Minnesota Health Care Programs (MHCP) without an active license, an approved MPSE enrollment, and a valid SA from a county, tribal nation, or Managed Care Organization (MCO).

1. Service Definition and Scope

In Minnesota, behavioral health services for HCBS recipients are categorized into specific service lines, primarily Positive Support Services, Specialist Services, and Crisis Respite. These services aim to increase a person's adaptive behaviors, decrease challenging behaviors, and provide immediate intervention during mental health crises.

Mental health clinic services, governed by Chapter 245I, cover diagnostic assessments, psychotherapy, and clinical care consultation. Providers must clearly define their scope of practice and align it with the specific waiver service definitions outlined in the DHS Community-Based Services Manual (CBSM).

• Positive Support Services: Develops and implements positive behavior support plans to reduce challenging behaviors.
• Specialist Services: Provides expert assessment and program design for individuals with complex behavioral needs.
• Crisis Respite: Offers short-term behavioral or medical intervention to protect the person or others.
• Diagnostic Assessment: Identifies a mental health diagnosis and develops a treatment plan under 245I.
• Psychotherapy: Delivers therapeutic interventions to address mental health conditions.
• Clinical Care Consultation: Provides clinical guidance to other providers supporting the individual.

2. Regulatory and Oversight Agencies

The Minnesota Department of Human Services (DHS) is the primary regulatory body for both licensure and Medicaid enrollment. Within DHS, the Licensing Division handles facility and program licenses, while the Provider Eligibility and Compliance division manages MHCP enrollment.

Lead agencies, which include counties, tribal nations, and Managed Care Organizations (MCOs), are responsible for assessing member needs and issuing service authorizations.

• Minnesota Department of Human Services (DHS): Oversees all Medicaid and HCBS programs (https://mn.gov/dhs/).
• DHS Licensing Division: Issues and monitors 245D and 245I licenses (https://mn.gov/dhs/licensing/).
• MHCP Provider Eligibility and Compliance: Processes MPSE portal enrollments (https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mpse/).
• Minnesota Department of Health (MDH): Regulates certain health care professionals and facilities (https://www.health.state.mn.us/).
• Blue Plus: Example of an MCO acting as a lead agency for service authorizations (https://www.bluecrossmn.com/blue-plus).

3. Gatekeeping Prerequisites: Who Can Even Apply

Minnesota requires providers to hold an active license before they can enroll in MHCP. For behavioral health and positive support services, this means obtaining a 245D Intensive Support Services license or a 245I Mental Health Clinic certification.

Additionally, providers must secure a DHS-approved service authorization (SA) from a lead agency (county, tribe, or MCO) to provide services to a specific eligible person. Without this SA, MHCP will not pay for services, even if the provider is licensed and enrolled.

• Licensure Prerequisite: Must hold an active 245D or 245I license from DHS Licensing before MPSE enrollment.
• Service Authorization (SA): Requires an approved SA from a lead agency case manager prior to service delivery.
• NPI Requirement: Must obtain a National Provider Identifier (NPI) before applying to MHCP.
• MCO Contracting: Providers serving MCO members must complete the MCO In-Network Provider Enrollment process.
• Application Fee: Must pay the nonrefundable MHCP application fee unless exempt or already paid to Medicare.

4. Licensure and Certification Requirements

Providers must apply for licensure through the DHS Licensing Division. For HCBS behavioral services, a 245D Intensive Support Services license is required, which mandates strict adherence to positive support strategies and prohibitions on restrictive interventions.

Mental health clinics must meet the certification standards of Minnesota Statutes, Chapter 245I, which includes requirements for clinical supervision, physical space, and administrative separation.

• 245D License Application: Requires submission of policies, procedures, and a business plan to DHS Licensing.
• 245I Certification: Requires proof of clinical supervision structures and qualified mental health professional staffing.
• Positive Support Rule: Must comply with Minnesota Rules, Chapter 9544 regarding the safe use of positive support strategies.
• Background Studies: All owners, managerial officials, and direct care staff must clear NETStudy 2.0 background checks.
• Site Inspections: DHS Licensing conducts pre-licensure and ongoing unannounced site visits.

5. Medicaid Provider Enrollment

Enrollment in Minnesota Health Care Programs (MHCP) is conducted online via the Minnesota Provider Screening and Enrollment (MPSE) portal. Providers must submit their active license, NPI, and completed HCBS Programs Service Request Form (DHS-6638).

The enrollment process includes screening for excluded providers and requires the setup of Electronic Funds Transfer (EFT) for payments.

• MPSE Portal: The mandatory online system for submitting MHCP enrollment applications.
• Form DHS-6638: The HCBS Programs Service Request Form used to specify which waiver services the provider will offer.
• EFT Setup: Requires submission of the EFT Supplier ID Notification (DHS-3725) or MPSE entry.
• Provider Agreement: Must sign and submit the MHCP Provider Agreement during enrollment.
• Revalidation: Providers must revalidate their MHCP enrollment every five years.

6. Staffing, Training and Background Checks

Staff qualifications are strictly defined by the service type. Positive Support Professionals must have specific degrees and experience in behavior analysis, while mental health services require licensed mental health professionals or practitioners under clinical supervision.

All staff must pass a background study through DHS NETStudy 2.0 before having direct contact with individuals receiving services.

• NETStudy 2.0: Mandatory DHS background study system for all direct contact staff.
• Positive Support Professional: Requires a master's degree in a relevant field and specific training in behavior analysis.
• Mental Health Professional: Must be licensed in Minnesota (e.g., LP, LICSW, LMFT, LPCC).
• Orientation Training: 245D requires specific orientation training on maltreatment reporting and the Positive Support Rule.
• Ongoing Training: Annual training requirements apply based on the specific license and service provided.

7. Documentation, Policies and Records

Providers must maintain comprehensive documentation to support billing and demonstrate compliance with licensing standards. This includes individualized service plans, progress notes, and incident reports.

Under 245D and 245I, providers must have written policies covering grievance procedures, maltreatment reporting, and emergency responses.

• Service Authorization (SA): Must retain copies of all approved SAs from lead agencies.
• Progress Notes: Daily or per-session documentation detailing the intervention, response, and progress toward goals.
• Positive Support Transition Plan: Required documentation when phasing out restrictive interventions.
• Maltreatment Policies: Written procedures for reporting suspected abuse or neglect under the Vulnerable Adults Act.
• Record Retention: MHCP requires providers to retain all service and billing records for at least five years.

8. Billing, Rates and Claims

Billing for MHCP fee-for-service claims is processed through the MN-ITS system. Providers must ensure that claims match the approved Service Authorization (SA) exactly, including procedure codes, modifiers, and units.

Rates for HCBS waiver services are determined by the Disability Waiver Rate System (DWRS) or established by the lead agency, depending on the specific service.

• MN-ITS: The mandatory electronic billing system for MHCP fee-for-service claims.
• Service Authorization Letters (SAL): Providers must verify accuracy in their MN-ITS mailbox before billing.
• DWRS Framework: Determines rates for many 245D services based on standardized state frameworks.
• Procedure Codes: Must use the specific HCPCS codes and modifiers listed on the approved SA.
• Timely Filing: Claims must generally be submitted within 12 months of the date of service.

9. Approval Sequence and Timeline

The approval process is sequential and can take several months. Providers must first obtain their NPI and complete the DHS Licensing process, which includes application review and site visits.

Once licensed, the MPSE enrollment process typically takes 30 to 90 days. Providers cannot begin delivering billable services until the MPSE enrollment is approved and a lead agency issues a Service Authorization.

• Step 1: Obtain NPI and register business with the Minnesota Secretary of State.
• Step 2: Submit 245D or 245I license application to DHS Licensing (timeline varies, often 3-6 months).
• Step 3: Submit MHCP enrollment via MPSE portal (processed within 30-90 days).
• Step 4: Receive MN-ITS welcome letter and register account.
• Step 5: Obtain Service Authorization from lead agency prior to service delivery.

10. Common Denials and Survey Findings

Licensing applications are frequently delayed or denied due to incomplete policy manuals or failure to meet specific staff qualification standards. During surveys, DHS commonly cites providers for inadequate documentation of positive support strategies.

MHCP enrollment applications are often returned for correction if the provider fails to pay the application fee, submits mismatched NPI information, or lacks the required underlying license.

• Policy Deficiencies: Generic or incomplete policies submitted during the 245D application process.
• Staff Qualifications: Failure to provide transcripts or licenses proving staff meet Positive Support Professional standards.
• Background Study Violations: Allowing staff to work before clearing NETStudy 2.0.
• Billing Discrepancies: Submitting claims in MN-ITS that do not match the authorized units or dates on the SA.
• Missing Forms: Failure to upload the HCBS Programs Service Request Form (DHS-6638) in MPSE.

11. Key Contacts and Resources

Providers should utilize the official DHS portals and manuals for the most current requirements. The Community-Based Services Manual (CBSM) and the MHCP Provider Manual are essential reference documents.

For enrollment assistance, providers can contact the MHCP Provider Resource Center or attend quarterly MPSE training webinars.

• MHCP Provider Manual: Comprehensive billing and policy guide (https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=id_000094).
• Community-Based Services Manual (CBSM): Policy manual for HCBS waivers (https://www.dhs.state.mn.us/main/idcplg?IdcService=GET_DYNAMIC_CONVERSION&RevisionSelectionMethod=LatestReleased&dDocName=id_000402).
• MPSE Portal: Enrollment system (https://mn.gov/dhs/partners-and-providers/policies-procedures/minnesota-health-care-programs/provider/mpse/).
• MN-ITS: Billing system (https://mn-its.dhs.state.mn.us/).
• DHS Licensing: Regulatory oversight (https://mn.gov/dhs/licensing/).

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