Virginia - Case Management Service — Licensing, Medicaid Enrollment and Startup Requirements
Last reviewed: 2026-09-10
The Virginia Department of Behavioral Health and Developmental Services (DBHDS) licenses Support Coordination/Case Management under 12VAC35-105, serving as the mandatory entry point for individuals accessing the state's Developmental Disability (DD) waivers. This service encompasses functional assessment, person-centered Individualized Services Plan (ISP) development, service linkage, and ongoing monitoring to ensure health and safety in the community.
Private agencies seeking to provide DD Support Coordination face a closed-network statutory framework, as the Code of Virginia designates local Community Services Boards (CSBs) and Behavioral Health Authorities (BHAs) as the exclusive operating entities for this service. Independent providers cannot enroll directly with Medicaid as standalone DD case managers; they must instead secure a formal subcontract or affiliation agreement with a local CSB that holds the primary Medicaid provider agreement for that catchment area.
1. Service Definition and Scope
In Virginia, Case Management (frequently termed Support Coordination for DD populations) is defined as services that assist individuals in gaining access to needed medical, social, educational, and other services. The service does not include the direct delivery of medical or clinical treatments, but rather the orchestration of the individual's entire HCBS waiver package.
The scope of practice requires the case manager to conduct initial and ongoing assessments, develop the ISP, link the individual to qualified waiver providers, and conduct regular face-to-face monitoring visits to verify that services are delivered according to the ISP and meet the individual's changing needs.
- Assessment: completion of the Virginia State Assessment (VIDES) to determine level of care eligibility
- Service Planning: development and annual revision of the person-centered Individualized Services Plan (ISP)
- Referral: linking individuals to DBHDS-licensed direct service providers and community resources
- Monitoring: conducting monthly or quarterly face-to-face visits to evaluate service efficacy and health status
- Documentation: maintaining detailed progress notes in the electronic health record for every billable contact
2. Regulatory and Oversight Agencies
Two primary state agencies govern case management services in Virginia. DBHDS handles the programmatic licensing, regulatory compliance, and quality oversight for all behavioral health and developmental disability services.
The Department of Medical Assistance Services (DMAS) serves as the state Medicaid agency, managing provider enrollment, establishing reimbursement rates, and operating the Medicaid Enterprise System (MES) for claims processing.
- DBHDS Main Agency: oversees behavioral health and developmental services (https://dbhds.virginia.gov/)
- DBHDS Office of Licensing: issues provider licenses and conducts compliance surveys (https://dbhds.virginia.gov/quality-management/Office-of-Licensing)
- DMAS Main Agency: administers the Virginia Medicaid program (https://www.dmas.virginia.gov/)
- DMAS Provider Portal: manages Medicaid enrollment and claims via the MES (https://vamedicaid.dmas.virginia.gov/provider)
- Local CSBs: act as the statutory gatekeepers and primary contractors for DD case management (https://vacsb.org/)
3. Gatekeeping Prerequisites: Who Can Even Apply
Virginia strictly limits who can provide DD Support Coordination. By statute, the 40 local Community Services Boards (CSBs) and Behavioral Health Authorities (BHAs) are the designated entities responsible for DD case management. A private entity cannot simply apply for a DBHDS license and DMAS enrollment to offer DD Support Coordination independently.
To operate in this space, a private agency must first secure a subcontract with a local CSB. The CSB retains the ultimate authority and Medicaid billing rights, delegating the operational duties to the subcontractor. Without this executed agreement, DMAS will not enroll the provider for DD case management.
- Statutory Designation: Code of Virginia restricts DD Support Coordination to local CSBs/BHAs
- Subcontracting Requirement: private agencies must hold an executed contract with a local CSB to provide DD case management
- Mental Health Exception: Mental Health Case Management has different network rules but still requires DBHDS licensure
- Geographic Boundaries: CSB contracts are strictly limited to the specific city or county catchment area they serve
- Need Review: CSBs only issue subcontracts if they determine a local capacity need exists that they cannot meet internally
4. Licensure and Certification Requirements
Providers must obtain a license from the DBHDS Office of Licensing under the administrative code 12VAC35-105. The application process requires submission of a comprehensive policy and procedure manual, proof of financial stability, and a detailed service description.
The DBHDS licensing process includes an initial application review followed by an on-site inspection. Providers must demonstrate compliance with human rights regulations, incident reporting protocols, and physical environment standards if operating a facility, though case management is primarily community-based.
- Regulatory Citation: licensure is governed by 12VAC35-105 (Rules and Regulations for Licensing Providers)
- Service Description: applicants must submit a detailed narrative of service goals, target population, and admission criteria per 12VAC35-105-580
- Policy Manual: requires comprehensive policies covering human rights, risk management, and emergency preparedness
- Initial Application: submitted via the DBHDS CONNECT provider portal
- Conditional License: newly approved providers typically receive a 6-month conditional license before full annual licensure
5. Medicaid Provider Enrollment
Once licensed by DBHDS and holding the necessary CSB affiliation (if applicable), providers must enroll with DMAS through the Medicaid Enterprise System (MES) Provider Registration and Service Authorization System (PRSS).
Enrollment requires an active National Provider Identifier (NPI), completion of a Participation Agreement, and successful provider screening. Out-of-state providers must be screened by their home state Medicaid program or Medicare prior to applying in Virginia.
- Enrollment Portal: applications are processed through the DMAS MES PRSS system
- NPI Requirement: providers must obtain an NPI from NPPES prior to application
- Application Fee: certain provider types must pay a $631 application fee unless previously screened by Medicare or another state
- Participation Agreement: authorized agents must sign the DMAS agreement binding them to state Medicaid rules
- Effective Date: the Medicaid enrollment effective date will never precede the DBHDS license effective date
6. Staffing, Training and Background Checks
Virginia mandates strict educational and experiential qualifications for case managers. Staff must typically meet the criteria for a Qualified Developmental Disabilities Professional (QDDP) or a Qualified Mental Health Professional (QMHP), depending on the target population.
Training requirements are rigorous and time-sensitive. DBHDS requires specific core competency training to be completed immediately upon hire, and all staff must pass comprehensive criminal background checks and central registry checks before providing direct services.
- Educational Standard: typically requires a bachelor's degree in a human services field (social work, psychology, etc.)
- Core Training: case managers must complete the DBHDS core competency-based curriculum within 30 days of hire
- Supervision: services must be supervised by a qualified professional with at least one year of documented experience
- Background Checks: mandatory Virginia State Police criminal history and DSS Child Protective Services registry checks
- Ongoing Education: staff must complete annual training on human rights, incident reporting, and person-centered practices
7. Documentation, Policies and Records
Case management providers must maintain exhaustive clinical and administrative records. The cornerstone of this documentation is the Individualized Services Plan (ISP), which must clearly link assessed needs to specific waiver services and goals.
Providers must also maintain detailed progress notes for every billable encounter. These notes must document the date, time, duration, location, and specific interventions provided, aligning directly with the objectives outlined in the ISP.
- ISP Development: must be updated annually or whenever the individual's needs change significantly
- Progress Notes: required for every billable contact, detailing the specific case management activity performed
- Assessments: must maintain current functional assessments (e.g., VIDES) in the individual's record
- Incident Reporting: mandatory use of the DBHDS CHRIS system for reporting serious incidents within 24 hours
- Record Retention: clinical records must typically be retained for a minimum of six years post-discharge
8. Billing, Rates and Claims
Reimbursement for case management services is processed through the DMAS MES using standard HIPAA-compliant transactions. Rates are established by the Virginia General Assembly and published in the DMAS fee schedules.
Billing is typically conducted on a monthly unit basis, requiring a minimum number of qualifying contacts (including face-to-face visits) to generate a billable claim. Providers must ensure that no duplicate billing occurs across different waiver programs.
- Claims System: submitted electronically via the DMAS MES portal or an approved clearinghouse
- Fee Schedule: rates are published on the DMAS website under the specific waiver or service category
- Unit of Service: often billed as a monthly rate contingent upon meeting minimum contact requirements
- Procedure Codes: specific HCPCS codes (e.g., T1016) are assigned based on the exact type of case management
- MCO Contracting: for populations under managed care, providers must also credential and contract with the specific CCC Plus MCOs
9. Approval Sequence and Timeline
The pathway to becoming a billable provider is strictly sequential. An applicant cannot apply for Medicaid enrollment until the DBHDS license is fully issued, and for DD services, the CSB contract must be secured first.
The entire process from initial DBHDS application to active DMAS billing status typically takes 6 to 9 months, heavily dependent on the completeness of the policy manual submission and the scheduling of the initial licensing site visit.
- Step 1: secure a subcontract or affiliation agreement with a local CSB (for DD services)
- Step 2: submit the initial licensure application and policy manual to DBHDS via CONNECT
- Step 3: undergo the DBHDS Office of Licensing initial on-site inspection
- Step 4: receive the conditional DBHDS provider license
- Step 5: submit the Medicaid enrollment application through the DMAS MES PRSS portal
10. Common Denials and Survey Findings
Licensing applications are frequently delayed due to incomplete or generic policy manuals that fail to address Virginia-specific regulations, particularly regarding human rights and incident management.
During compliance surveys, the most common citations involve missing or late DBHDS core competency training certificates, ISPs that lack measurable goals, and progress notes that do not adequately justify the billed time.
- Training Deficiencies: failure to complete the DBHDS core competency curriculum within the mandatory 30-day window
- Generic Policies: submitting purchased policy manuals that are not customized to 12VAC35-105 requirements
- Documentation Gaps: progress notes that lack specific start/stop times or fail to link to ISP goals
- Background Check Errors: allowing staff to provide billable services before background check results are fully returned
- Late Reporting: failure to enter serious incidents into the CHRIS system within the required 24-hour timeframe
11. Key Contacts and Resources
Prospective providers should rely exclusively on official state resources for the most current regulations, forms, and fee schedules. The DBHDS and DMAS websites house all necessary manuals and portal links.
For DD case management specifically, the local CSB in the intended service area is the most critical initial contact, as they control network access.
- DBHDS Office of Licensing: manages provider applications and regulations (https://dbhds.virginia.gov/quality-management/Office-of-Licensing)
- DMAS Provider Enrollment: handles MES PRSS portal issues (https://vamedicaid.dmas.virginia.gov/provider)
- Virginia Town Hall: hosts the official text of 12VAC35-105 and proposed regulatory changes (https://townhall.virginia.gov/)
- Virginia Association of Community Services Boards: directory of local CSBs for subcontracting inquiries (https://vacsb.org/)
- DBHDS CONNECT Portal: the electronic system for submitting licensing applications and updates (https://dbhds.virginia.gov/quality-management/Office-of-Licensing/connect/)
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