Behavioral Health Changes Nationwide

What changed. DHCS posted a draft Behavioral Health Information Notice on September 25, 2026 that clarifies Medi-Cal managed care plans are responsible for covering and reimbursing providers for emergency services and care, including psychiatric emergencies, and any post stabilization care services. The draft says this applies whether the member is voluntary or involuntarily detained, and that fee for service Medi-Cal pays for members not enrolled in a managed care plan. DHCS asks for feedback to CountySupport@dhcs.ca.gov by October 12, 2026.

What it means. Hospitals, crisis programs and psychiatric emergency providers that have had emergency claims denied or redirected between managed care plans and county plans should read the draft and send comments by October 12. Billing teams should compare their current payer routing for psychiatric emergency and post stabilization claims against the draft so they are ready when DHCS issues the final notice.

What changed. The Colorado Behavioral Health Administration lists State Board of Human Services readings on September 4 and October 9, 2026 for its Fall 2026 Provider Rules Packet, SBHS identification number 25-04-22-01, which updates 2 CCR 502-1 to align the behavioral health continuum with the adult volume of the ASAM Criteria. The packet revises Chapter 1 and Chapters 4 through 7, covering general standards, outpatient and high intensity outpatient services, residential services, crisis services, and emergency and involuntary SUD commitment services, with an anticipated effective date of July 1, 2027.

What it means. Colorado outpatient, residential and crisis operators should read the clean and redline chapter drafts posted by the BHA and note where their level of care designations and policies will need to change. Calendar the anticipated July 1, 2027 effective date and send any concerns to the BHA rule feedback address before the board acts.

What changed. The October 2026 Medicaid Provider Manual update, effective October 1, 2026, revises the definitions of Qualified Mental Health Professional and Qualified Intellectual Disability Professional in the Behavioral Health and Intellectual and Developmental Disability Supports and Services chapter. It states that a PIHP may not deny services based solely on preset limits of the cost, amount, scope and duration of services. Eligibility sections for specialty behavioral health and children's services now reference MichiCANS Decision Support Models to indicate potential need.

What it means. Compare your staff qualification records and job descriptions against the revised QMHP definition in the October 2026 manual. If you contract with a PIHP, review how service authorizations are decided and documented under the updated PIHP decisions section and the MichiCANS references.

What changed. NC Medicaid announced on October 2, 2026 that its amended Clinical Coverage Policy 8G, Peer Support Services, became effective upon promulgation on September 1, 2026, for NC Medicaid Direct and NC Medicaid Managed Care. The amendment adds prior authorization, concurrent review and reauthorization guidance, requires service notes to show start and end times, requires providers to keep a roster of NC Certified Peer Support Specialists available on request, and clarifies that only NC Certified Peer Support Specialists may bill for the service.

What it means. Peer support programs billing NC Medicaid should compare their authorization workflow, note templates and telehealth share against the amended policy now in effect. Keep a current roster of certified peer support specialists ready to hand to NCDHHS or your health plan on request.

What changed. Beginning October 1, 2026, appointment dates and times are no longer scheduled for the federally required site visits of Medicaid providers classified as moderate and high risk, which Public Consulting Group performs for NC Medicaid. Providers instead receive notice that a visit will occur within a specified timeframe, and failure to grant prompt and reasonable access may result in suspension of the provider, its reimbursements or its participation.

What it means. Programs enrolling or revalidating with NC Medicaid should make sure front desk staff on every shift know how to receive a Public Consulting Group site visitor during normal business hours. If your site completed a Medicare site visit within the past five years, note it on your application, since NC Medicaid says you will not need another visit at this time.

What changed. DHCS issued BHIN 26-031 on October 5, 2026, telling county behavioral health plans how to claim Medi-Cal for evidence-based practices, other Full Service Partnership services and other BHSS Early Intervention services under the Behavioral Health Services Act. High Fidelity Wraparound must be billed with the monthly code H2022 with modifier 12, and unbundled claiming is not permitted for it. Other FSP and Early Intervention services are claimed as unbundled SMHS, DMC or DMC-ODS services with tracking modifiers that must be used on claims with dates of service of January 1, 2027 or later.

What it means. Providers that deliver FSP, ACT, FACT, coordinated specialty care, supported employment or Early Intervention services under a county contract should ask their county plan which codes and modifiers it will require on claims starting January 1, 2027. Billing staff should plan EHR and claim form updates before that date, since DHCS says it will notify plans when the modifiers are available in Short-Doyle Medi-Cal.

What changed. DHCS issued BHIN 26-030, dated August 19, 2026, which supersedes BHIN 22-016 and sets how county Mental Health Plans authorize specialty mental health services. Plans may not require prior authorization for services such as crisis intervention, medication support and targeted case management, must use concurrent review rather than prior authorization for crisis residential and adult residential treatment, and may require prior authorization or plan referral for day treatment intensive, day rehabilitation, Therapeutic Behavioral Services, Therapeutic Foster Care, ACT and FACT. Standard prior authorization decisions are due within five business days of receiving the needed information and expedited decisions within 72 hours.

What it means. Specialty mental health providers contracted with a county plan should confirm which of their services still need prior authorization or referral and which now move to concurrent review or need none. Intake and utilization review staff should track county response times against the five business day and 72 hour limits and raise delays with the plan.

What changed. The department filed an amendment on July 13, 2026 that combines the adult, family and youth peer support specialist rules into 908 KAR 2:220, and a companion rule, 908 KAR 2:311, repeals 908 KAR 2:230 and 908 KAR 2:240. The proposal requires at least 60 hours of initial training, supervision at least twice a month with at least one session one on one, and certification under the new rule beginning July 1, 2027. Current certified peer support specialists who are not approved for a waiver would have to complete the entire certification process by January 1, 2028. Written comments closed September 30, 2026.

What it means. Programs that employ peer support specialists should list which staff hold adult, family or youth certifications and follow this rule to final adoption. If it is adopted as filed, training and supervision schedules may need to change before July 1, 2027.

What changed. For claims with dates of service on or after January 1, 2027, a claim will not be payable if a provider named on it as ordering, referring, prescribing, attending, supervising or operating is not enrolled with MassHealth on the date of service. MassHealth already requires billing, ordering, rendering, referring and prescribing providers to enroll, and has been posting informational denial messages on remittance advices for unenrolled attending, supervising and operating providers. Psychologists, Licensed Independent Clinical Social Workers and Psychiatric Clinical Nurse Specialists are listed as eligible attending or supervising providers.

What it means. Check that every clinician your claims list as attending or supervising is enrolled with MassHealth before January 1, 2027, including supervisors of staff who bill under supervision. Review your remittance advices now for the informational denial codes listed in the bulletin so you can fix enrollment gaps before claims start to deny.

What changed. Master's level Temporary Limited Licensed Psychologists, Limited Licensed Counselors, Educational Limited Licensed Marriage and Family Therapists and Limited Licensed Master's level Social Workers must enroll in CHAMPS as Rendering Only providers tied to an organizational billing provider and a fully licensed, Medicaid enrolled supervisor. Already enrolled providers do not need to re-enroll but must add their supervisor association by November 1, 2026, to avoid disenrollment and claim denials. For dates of service on or after September 1, 2026, professional claims list the limited licensed provider's NPI as rendering, and payment goes to the billing provider; the bulletin's enrollment and billing instructions do not apply to PIHPs and PIHP providers.

What it means. Confirm that each limited licensed clinician on your Michigan Medicaid fee for service or health plan claims is enrolled as Rendering Only and associated with a supervisor's NPI in CHAMPS before November 1, 2026. Check that your claims now report the clinician, not the supervisor, as the rendering provider and that your organization bills under a Type 2 NPI.

What changed. Two men who enrolled Pristine Health LLC as a Medicaid provider pleaded guilty to wire fraud for submitting Housing Stabilization Services claims for services that were never provided and inflating claims for higher reimbursement. The now-defunct program was meant to help people with disabilities, including people with mental illnesses and substance use disorders, find and keep housing. Pristine Health enrolled about 90 beneficiaries, including some who never agreed to receive services, and billed Minnesota Medicaid more than $820,000.

What it means. Confirm that every Medicaid member you bill has a signed consent or enrollment record for the specific service and that each claim matches a documented contact of the billed type and length. If you bill housing support, case management or other non-clinical Medicaid services, audit a sample of claims against visit notes and member signatures this quarter.

What changed. The Office of Mental Health filed a Notice of Proposed Rulemaking for Part 551 of Title 14 of the NYCRR, relating to the operation of psychiatric inpatient units of general hospitals and the Prior Approval Review process. The proposal was published in the September 16, 2026 State Register on page 12 (Issue 37), and the public comment period ends November 15, 2026.

What it means. Hospitals that run or plan psychiatric inpatient units in New York should review the proposed text for how bed additions, reductions and closures would move through Prior Approval Review. Send any comments to regs@omh.ny.gov before November 15, 2026.

What changed. The registered agent of nLove Community Services LLC, which purported to provide mental health therapy to Medicaid beneficiaries, pleaded guilty to health care fraud and aggravated identity theft. She admitted billing Medicaid approximately $477,872 for therapy that was never provided, including services billed as provided to herself, and the company received approximately $453,323. She used a nurse practitioner's name and National Provider Identifier to submit claims without the practitioner's knowledge or consent.

What it means. Check that every claim lists a rendering provider who actually delivered and documented the session, and that each clinician's NPI is used only with their knowledge on your claims. Have each clinician review a sample of claims billed under their NPI and ask payers or clearinghouses for any claims submitted under it that you cannot match to a note.

What changed. The Department of Health filed a CR-101 and is considering repealing chapter 246-324 WAC, Private Alcohol and Chemical Dependency Hospitals, to reduce regulatory burden and remove overlap with chapter 246-322 WAC. The department says a rulemaking meeting will be held October 13, 2026, and more meetings may follow.

What it means. Hospitals licensed under chapter 246-324 WAC should review which of their current requirements would shift to chapter 246-322 WAC if the chapter is repealed. Calendar the October 13 meeting and register through the department's rules in progress page to give input.

What changed. The Department of Health filed a CR-101 on September 11, 2026, to begin rulemaking to update chapter 246-337 WAC, the residential treatment facility licensing rules. A survey sent to interested parties on September 17 closes October 9, after which the department will announce a kickoff webinar and workshops.

What it means. Licensed residential treatment facilities should list the chapter 246-337 WAC requirements that cause them the most trouble and submit them before the survey closes. Watch for the kickoff webinar and workshop dates, since that is where draft language will first be discussed.

What changed. The Department of Health filed a CR-101 to amend opioid treatment program rules in chapter 246-341 WAC for general cleanup, revised fixed-site medication unit requirements and standards for emerging dispensing technology. Workshops are scheduled from 9:00 to 10:00 a.m. on October 6, 8, 13 and 15, 2026, with an extra session on October 20 if needed.

What it means. Opioid treatment programs, especially those running or planning fixed-site medication units or automated dispensing, should send someone to the remaining workshops. Bring specific examples of current rule language that conflicts with operations so they can be raised before draft rules are written.

What changed. The Bureau of Justice Assistance posted its FY 2026 Adult Treatment Court Program on September 21, 2026, to support the implementation and enhancement of adult treatment court operations that prevent overdoses and reduce the use of opioids, stimulants and other substances among high-risk, high-need adults in the criminal justice system. The Grants.gov listing names state, county, city or township and federally recognized tribal governments as eligible applicants and states that cost sharing or matching is required. The Grants.gov closing date is October 30, 2026.

What it means. The listing names government applicants, so a treatment provider that serves an adult treatment court should contact the court, county or state agency now about being named as a treatment partner before October 30. Read the full BJA solicitation for award sizes and the match requirement before committing staff time.

What changed. Optum Behavioral Health says CMS requires annual Model of Care training for both network and out-of-network providers who serve members of Dual Special Needs Plans (D-SNP), who are eligible for both Medicare and Medicaid. Providers who serve UnitedHealthcare Community Plan or Optum Behavioral Health D-SNP members must complete the training and its attestation by Dec. 31, 2026. Attestations are reported monthly because CMS may request a copy.

What it means. Programs that see dual-eligible members through UnitedHealthcare or Optum should confirm that each clinician who serves them has completed the applicable course and attestation before Dec. 31, 2026. Keep a copy of each attestation in credentialing files, since other Medicare plans may ask for their own annual training as well.