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Washington BHA Deemed Status: CARF, Joint Commission or COA

As of November 2026, Washington's Department of Health deems a behavioral health agency accredited by CARF, The Joint Commission or the Council on Accreditation as meeting state licensing standards. Deemed agencies skip routine DOH on-site reviews and pay lower license fees, but still need a standard license, an initial DOH review and full compliance with state law.

Saint Health Group·November 10, 2026 · 9 min read

A Washington State ferry crossing Puget Sound in fog, for a guide to deemed status for Washington behavioral health agencies
A Washington State ferry crossing Puget Sound in fog, for a guide to deemed status for Washington behavioral health agencies

In Washington, national accreditation changes how the state licenses you. A behavioral health agency accredited by a body that has an agreement with the Department of Health can be deemed as meeting state minimum standards, which ends routine state on-site reviews and cuts the annual licensing fee. Deemed status is narrower than many operators assume, though, and the order you do things in matters.

This guide is for owners and compliance directors of Washington behavioral health agencies weighing CARF, The Joint Commission or the Council on Accreditation. If you are still getting licensed, start with our Washington behavioral health agency licensing guide.

What is deemed status for a Washington behavioral health agency?

RCW 71.24.037 directs the Secretary of Health to provide for deeming of licensed or certified behavioral health agencies as meeting state minimum standards as a result of accreditation by a recognized behavioral health accrediting body that has a current agreement with the department. WAC 246-341-0200 defines "deemed" the same way, as a status given to a licensed agency, and WAC 246-341-0310 sets out how it works.

The practical effect is in WAC 246-341-0320. Every agency gets an initial on-site review, but only agencies that are not deemed are subject to routine, ongoing DOH on-site reviews. DOH's inspection process page puts it plainly: deemed agencies are reviewed by the accrediting organization rather than receiving regularly scheduled inspections by the department. The same page says the state licenses more than 900 behavioral health agencies.

Which accrediting bodies does Washington DOH recognize?

As of November 2026, DOH's inspection process page lists agreements with three organizations, each linked to a signed memorandum of understanding:

One detail worth checking before you build a plan around it: the CARF and COA copies DOH posts state a term running through June 30, 2024, while the page still lists all three as current agreements. Confirm with DOH that the agreement for your accreditor is in force when you apply. DOH's deeming application (DOH 611-013) offers the same three choices.

Opioid treatment programs are a separate track. DOH's OTP accreditation page says a proposed OTP must obtain accreditation from a SAMHSA-approved accreditation body against the federal standards in 42 CFR Part 8, and lists four options: DOH itself, CARF, The Joint Commission and COA. Our Washington OTP licensing guide covers that path.

What changes once an agency is deemed, and what stays with DOH?

All three memoranda divide the work the same way. Standards that match between the accreditor and the state are treated as equal to the WAC requirements, and every other standard stays DOH's responsibility. The Joint Commission memorandum says outright that it does not survey state-specific program requirements with no matching Joint Commission standard.

ItemNot deemedDeemedSource
Initial DOH on-site reviewRequiredRequired for a new main site or a new serviceWAC 246-341-0310 and 0320
Routine, ongoing DOH on-site reviewsYesNo; the accreditor surveysWAC 246-341-0320
Annual license feeFull rateDeemed rateWAC 246-341-0365
New agencies, branches, services, relocations, ownership changesDOHStill DOHEach memorandum, section I.C
Complaints, suspensions, revocations, sanctions under the WACDOHStill DOHEach memorandum, section I.C
State and federal statutes and regulationsApplyApply; never waived by deemingWAC 246-341-0310(6)(b)
Accreditation reports, audits and findingsNot applicableCopies go to DOHWAC 246-341-0310(7)

Residential programs should note one more limit. A residential treatment facility also holds a facility license under chapter 246-337 WAC, and that chapter has no deeming provision. Deemed status applies to the behavioral health agency license and certifications under chapter 246-341 WAC. Our Washington residential treatment facility guide covers the facility side.

How much does deemed status save on Washington license fees?

WAC 246-341-0365 sets two fee columns, with and without deemed status. Each agency files an annual form that reports its national accreditation status, its licensed beds and its annual outpatient service hours, which is how DOH places it on the schedule. Outpatient fees as of November 2026:

Annual outpatient service hoursWithout deemed statusWith deemed statusDifference
0 to 3,999$1,650$830$820
4,000 to 14,999$2,400$1,200$1,200
15,000 to 29,999$3,200$1,600$1,600
30,000 to 49,999$4,750$2,380$2,370
50,000 or more$5,800$2,900$2,900

For residential and inpatient services, the rule sets $250 per licensed bed without deemed status and $125 with it. DOH's fee page shows the deemed rate for inpatient substance use disorder beds and lists inpatient mental health beds at $250 with no deemed rate, so confirm the mental health bed rate with DOH before you budget on the lower figure.

Application fees do not change with deemed status: $2,250 for a new agency, $1,150 for a branch, $450 to add certifications and $1,150 for a change of ownership. Neither does the $2,250 investigation fee for a substantiated complaint or critical incident that requires corrective action.

The fee savings alone rarely pay for accreditation. They are a few hundred to a few thousand dollars a year against survey fees, preparation time and the standards work, which our breakdown of CARF accreditation costs walks through. The stronger case is operational: one survey cycle run by the accreditor instead of routine state reviews on top of it.

How do you get deemed status in Washington?

The order is fixed by the rule and the memoranda. Accreditation comes on top of a state license; it does not replace getting one.

  1. Hold a standard license. Each memorandum requires a standard license or certification from DOH for the services to be deemed, verified by at least one DOH on-site survey. Tribal organizations are exempt from that survey unless the tribe elects otherwise.
  2. Earn accreditation that covers the services. WAC 246-341-0310 asks for proof of accreditation for the services the agency provides, so a survey that left out a certified service leaves that service on the non-deemed track.
  3. File the deeming application. DOH 611-013 is completed separately for the main agency and for each branch. It asks for the most recent survey report and cover letter, the current accreditation certificate, the agency's hiring policy and procedures, any plan of correction and the accreditor's approval of it, and any annual declaration to the accreditor since the last survey.
  4. Sign the declarations. The administrator initials that the agency meets every Washington statute and rule on top of the accreditor's standards, and that DOH and the accreditor share survey reports, investigations and corrective action plans. Any requirement not initialed needs a plan of correction with completion dates.
  5. Keep DOH copied. Under WAC 246-341-0310(7), a deemed main site or branch sends DOH a copy of any relevant reports, audits, findings or documentation related to accreditation status.

Growth after deeming follows WAC 246-341-0310 as well. A new branch that offers the same services as a deemed main site, or a service added at a branch that is already deemed at the main site, needs only proof of accreditation. A new main site, a new type of certification or a branch service the main site does not offer needs proof of accreditation and a DOH initial on-site review.

CARF, Joint Commission or COA: which fits a Washington agency?

For deeming, Washington treats the three the same. Each memorandum lists the same WAC 246-341 areas that may be deemed in whole, requires the survey team to have at least two years of relevant experience in chemical dependency and mental health treatment, and makes sharing survey information with DOH a condition of deeming. The differences in the text are small:

  • What you send DOH. The CARF and COA memoranda name survey reports, corrective action plans and the agency's response. The Joint Commission memorandum names survey reports and evidence of standards compliance.
  • What the accreditor tells DOH. CARF and COA notify DOH of unresolved complaints or findings that lead to suspension or withdrawal of accreditation; The Joint Commission notifies DOH of those that lead to an adverse accreditation decision or withdrawal, consistent with its public information policy.

So the choice turns on the program, not the state. Program type, payer and referral expectations, and how each body surveys matter far more, and our CARF versus Joint Commission comparison covers them. For CARF specifically, see the CARF accreditation guide.

Frequently asked questions

Does deemed status replace a Washington behavioral health agency license?

No. Deeming applies to an agency that already holds a DOH license. Each DOH memorandum requires a standard license or certification for the deemed services, verified by at least one DOH on-site survey, before an agency can be deemed.

Which accreditors qualify for deemed status in Washington?

DOH lists agreements with The Joint Commission, the Council on Accreditation and CARF International. The CARF and COA copies DOH posts state a term through June 30, 2024 while DOH still lists them as current, so confirm the agreement with DOH when you apply.

Will DOH still inspect a deemed agency?

Not on a routine schedule. WAC 246-341-0320 exempts deemed agencies from routine, ongoing on-site reviews, but a new main site or new type of service still gets a DOH initial on-site review, and complaints and sanctions stay with DOH.

How much do deemed agencies save on fees?

Under WAC 246-341-0365, outpatient fees run $830 to $2,900 a year with deemed status against $1,650 to $5,800 without, depending on annual service hours. Residential and inpatient beds are $125 with deemed status and $250 without. Application fees are the same either way.

Does deemed status cover a residential treatment facility license?

No. Deeming applies to the behavioral health agency license and certifications under chapter 246-341 WAC. The residential treatment facility license under chapter 246-337 WAC has no deeming provision.

Accreditation and Washington licensing with one partner

Saint Health Group runs the whole sequence: the DOH license and initial review, the accreditation choice, the policies and documentation an accreditor surveys, the mock survey and the deeming application, with the WAC requirements an accreditor does not cover kept in the same manual. See our Washington licensing consulting and licensing and accreditation services, or talk with us about your agency.

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