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

Last reviewed: 2026-09-10

North Dakota Health and Human Services (HHS) funds Assessment, therapy, positive behavior support, and crisis response under the Behavioral Health Rehabilitative Services state plan benefit, updated under TN No. 24-0014 effective July 1, 2024. Approval requires practitioners to hold active licensure from their respective North Dakota professional boards or the HHS Behavioral Health Division before submitting an electronic application through the ND Health Enterprise MMIS portal.

Agencies operating as Licensed Addiction Programs must secure facility licensure directly from the Behavioral Health Division prior to Medicaid enrollment. Individual practitioners, including Licensed Master Social Workers (LMSW) and Licensed Associate Professional Counselors (LAPC), must enroll and bill under their own National Provider Identifier (NPI) rather than a supervising provider's NPI, enforcing a strict independent credentialing gate for all rendering staff.

1. Service Definition and Scope

ND Medicaid defines Behavioral Health Rehabilitative Services as short-term behavioral interventions designed to reduce undesirable behaviors and introduce positive alternative behaviors, including life skills improvement. Services encompass individual and group counseling, skills training, and behavior modification.

These services are intended to be brief, solution-focused, and outcome-based, targeting specific behavioral health needs identified through formal assessments.

• Service Limits: Individual counseling is limited to one hour per child per day without prior authorization.
• Group Counseling: Limited to one hour per child per day, requiring appropriate modifiers if billed in a group setting.
• Skills Training: Limited to four hours per day and must be within the practitioner's scope of practice.
• Intensive In-Home Services: Average length of service is two to six months; services beyond six months require thorough documentation and are subject to audit.

2. Regulatory and Oversight Agencies

The North Dakota Department of Health and Human Services (HHS) oversees both the programmatic rules and the Medicaid enrollment for these services. The Behavioral Health Division specifically licenses addiction programs, while individual professional boards govern practitioner licenses.

The ND Health Enterprise MMIS portal serves as the central hub for provider enrollment, claims submission, and eligibility verification.

• North Dakota HHS: https://www.hhs.nd.gov
• ND Medicaid Provider Enrollment: https://www.hhs.nd.gov/healthcare/medicaid/provider/enrollment-information
• ND Health Enterprise MMIS Portal: https://www.hhs.nd.gov/healthcare/medicaid/provider
• HHS Behavioral Health Division: https://www.hhs.nd.gov/behavioral-health

3. Gatekeeping Prerequisites: Who Can Even Apply

North Dakota does not impose a Certificate of Need (CON), closed network moratorium, or county sponsorship requirement for individual behavioral health practitioners. The primary structural precondition is that all rendering providers must hold full, active licensure from their respective North Dakota regulatory board or the Behavioral Health Division before initiating the Medicaid enrollment process.

Unlike states that allow extensive billing under agency umbrellas, North Dakota mandates that fully licensed behavioral health practitioners enroll independently.

• Independent NPI Requirement: Eligible providers must enroll and bill with their own NPI; they may not bill for services under a supervising or peer provider's NPI.
• Facility Licensure: Licensed Addiction Programs must obtain current licensure as an addiction program from the HHS Behavioral Health Division prior to enrollment.
• Border State Exception: Practitioners with similar licenses in border states may enroll by attesting to the Single State Medicaid Agency, provided they operate within their scope.
• Exclusion Checks: Applicants must be free of any exclusions from federally funded programs, including the LEIE and SAM databases.

4. Licensure and Certification Requirements

Individual practitioners must meet specific educational and board certification standards to qualify as rendering providers. Unlicensed health care trainees registered with their respective boards may provide services, but these must be billed through a supervising provider's NPI.

The state defines distinct educational pathways for behavior modification specialists, allowing both master's and bachelor's level professionals to qualify under specific conditions.

• Licensed Addiction Counselor: Requires current licensure by the North Dakota Board of Addiction Counseling Examiners.
• Behavior Modification Specialist (Master's): Requires a Master's degree in psychology, social work, counseling, education, or related field.
• Behavior Modification Specialist (Bachelor's): Requires a Bachelor's degree plus two years of professional work experience supervised by a licensed practitioner.
• Behavior Analyst: Requires licensure as a Board-Certified Behavior Analyst.

5. Medicaid Provider Enrollment

Enrolling in ND Medicaid is a four-step process managed entirely online through the ND Health Enterprise MMIS portal. Providers must first verify they are not already enrolled before submitting a new application.

Out-of-state providers delivering telehealth services must complete specific attestations to bypass standard out-of-state authorization requirements.

• Step 1 Search: Providers must search the Individual or Group NPI taxonomy lists on the HHS website to confirm no current enrollment exists.
• Step 2 Application: All providers must apply electronically on the ND Health Enterprise MMIS portal.
• Taxonomy Codes: Providers must submit appropriate taxonomy codes identifying their specialty when enrolling and submitting claims.
• Telehealth Attestation: Out-of-state providers delivering telehealth to ND members must submit the OOS Telehealth Attestation form.

6. Staffing, Training and Background Checks

Staffing qualifications are strictly tied to the practitioner's professional license and scope of practice. Agencies must ensure that all rendering staff maintain active credentials and adhere to board-specific supervision requirements.

Background checks are integrated into the Medicaid enrollment process through federal database verifications.

• Scope of Practice: All services must be recommended by an Ordering/Referring/Prescribing (ORP) provider and delivered within the practitioner's legal scope.
• Supervision Rules: Practitioners governed by a state licensing board must follow that specific board's requirements for clinical supervision.
• Trainee Billing: Unlicensed health care trainees must be registered with their professional board to have services billed under a supervisor.
• Background Clearances: Providers must pass standard Medicaid exclusion checks (LEIE, SAM) during the enrollment process.

7. Documentation, Policies and Records

ND Medicaid requires rigorous documentation to substantiate the medical necessity and delivery of behavioral health rehabilitative services. Treatment plans must be individualized and regularly updated.

Providers are responsible for verifying member eligibility on the exact date of service to ensure claims are processed correctly.

• Treatment Plan Updates: Behavior modification plans must be reviewed and modified at least monthly to ensure appropriate interventions.
• Plan Components: Plans must include stimulus control strategies, reinforcement strategies, and generalization plans.
• Extended Service Documentation: Intensive In-Home Services provided beyond six months require thorough documentation in the child's plan of care and are subject to audit.
• Eligibility Verification: Providers must verify member eligibility on the date of service using the MMIS Portal or Automated Voice Response System.

8. Billing, Rates and Claims

Claims are processed through the ND Health Enterprise MMIS, requiring specific HCPCS codes and modifiers depending on the service setting and provider type. Rates and specific authorization requirements are maintained in the Procedure Code Look-up Tool.

Federal regulations strictly prohibit Medicaid reimbursement for these services when delivered in certain institutional settings.

• Counseling Code: Billed using HCPCS code H0004 for Behavioral Health Counseling and Therapy.
• Behavioral Services Code: Billed using HCPCS code H2019 for Therapeutic behavioral services.
• Group Modifiers: Skills training provided in a group setting must be billed with the appropriate modifiers to distinguish it from individual services.
• IMD Restriction: Federal financial participation is not available for services provided to Medicaid members residing in an Institution for Mental Diseases (IMD).

9. Approval Sequence and Timeline

The approval sequence begins with securing professional or facility licensure, followed by the Medicaid enrollment application. The state processes applications through the MMIS portal, with effective dates tied to the completion of all requirements.

Providers must not submit duplicate applications if they are already listed in the state's active NPI directory.

• Phase 1: Obtain individual professional licensure or Behavioral Health Division facility licensure.
• Phase 2: Complete the NPI search to ensure no duplicate enrollment exists in the ND system.
• Phase 3: Submit the electronic application via the ND Health Enterprise MMIS portal.
• Phase 4: Submit required supporting documentation, including the OOS Telehealth Attestation if applicable, to finalize the effective date.

10. Common Denials and Survey Findings

Enrollment and claim denials typically stem from credentialing errors or failure to adhere to strict billing rules regarding NPIs. Audits frequently target services that exceed standard duration limits without proper authorization.

Failure to append correct modifiers for group settings is a frequent cause of claim rejection.

• NPI Billing Errors: Denials occur if eligible behavioral health providers attempt to bill under a supervising provider's NPI instead of their own.
• Duration Limit Audits: Intensive In-Home Services extending beyond the six-month average are subject to audit if the plan of care lacks thorough justification.
• Duplicate Enrollment: Applications are rejected if the provider fails to check the NPI taxonomy list and submits an application for an already enrolled NPI.
• Missing Modifiers: Claims for group skills training are denied if submitted without the required group-specific modifiers.

11. Key Contacts and Resources

Providers must utilize the official North Dakota HHS portals and manuals for current policies, rates, and enrollment instructions. The Behavioral Health Rehabilitative Services Billing and Policy Manual is the primary reference document.

The Automated Voice Response System serves as a backup for eligibility verification when the web portal is inaccessible.

• ND HHS Provider Enrollment: https://www.hhs.nd.gov/healthcare/medicaid/provider/enrollment-information
• ND Health Enterprise MMIS Portal: https://www.hhs.nd.gov/healthcare/medicaid/provider
• Automated Voice Response System: 1-877-328-7098
• HHS Behavioral Health Division: https://www.hhs.nd.gov/behavioral-health

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