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			30 text MINDFUL COMPLIANCE  / LISTEN & READ
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			32 text LISTEN & READ
			33 heading The Briefing, Value: 1
				34 text The Briefing
			35 text Press play and the paragraph being read lights up. Tap any paragraph to play from there. Your place is saved on this device. 49 min audio 16 sections 7,582 words
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		39 container Sections
			40 button 00 Before you start Start · 0:25
				41 text 00
				42 text Before you start
				43 text Start · 0:25
			44 button 01 How to use this Intro · 0:18
				45 text 01
				46 text How to use this
				47 text Intro · 0:18
			48 button 02 The whole thing in five minutes Part One · 2:11
				49 text 02
				50 text The whole thing in five minutes
				51 text Part One · 2:11
			52 button 03 Who's who, and who makes the rules Part Two · 2:36
				53 text 03
				54 text Who's who, and who makes the rules
				55 text Part Two · 2:36
			56 button 04 The two programs Part Three · 6:24
				57 text 04
				58 text The two programs
				59 text Part Three · 6:24
			60 button 05 A client's path, and every clock on it Part Four · 3:49
				61 text 05
				62 text A client's path, and every clock on it
				63 text Part Four · 3:49
			64 button 06 Medical necessity and utilization review: how approvals are actually won Part Five · 4:25
				65 text 06
				66 text Medical necessity and utilization review: how approvals are actually won
				67 text Part Five · 4:25
			68 button 07 Denials and appeals: the five tracks Part Six · 5:13
				69 text 07
				70 text Denials and appeals: the five tracks
				71 text Part Six · 5:13
			72 button 08 Audits: who shows up, what they check, and how to respond Part Seven · 6:30
				73 text 08
				74 text Audits: who shows up, what they check, and how to respond
				75 text Part Seven · 6:30
			76 button 09 Documentation that survives an audit Part Eight · 2:18
				77 text 09
				78 text Documentation that survives an audit
				79 text Part Eight · 2:18
			80 button 10 Getting paid correctly Part Nine · 2:31
				81 text 10
				82 text Getting paid correctly
				83 text Part Nine · 2:31
			84 button 11 Licenses, enrollment, people, and incidents Part Ten · 3:25
				85 text 11
				86 text Licenses, enrollment, people, and incidents
				87 text Part Ten · 3:25
			88 button 12 Privacy: HIPAA, and the stricter addiction-records rule Part Eleven · 2:43
				89 text 12
				90 text Privacy: HIPAA, and the stricter addiction-records rule
				91 text Part Eleven · 2:43
			92 button 13 The legal lines you never cross Part Twelve · 1:36
				93 text 13
				94 text The legal lines you never cross
				95 text Part Twelve · 1:36
			96 button 14 Leverage: parity and the plan's own rules Part Thirteen · 1:32
				97 text 14
				98 text Leverage: parity and the plan's own rules
				99 text Part Thirteen · 1:32
			100 button 15 What's changing right now, and how to think like an expert Part Fourteen · 3:10
				101 text 15
				102 text What's changing right now, and how to think like an expert
				103 text Part Fourteen · 3:10
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				109 checkbox (settable, integer) Description: Follow along, Value: 1, ID: follow
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			111 container part-0
				112 button Play from Before you start
					113 heading Before you start, Value: 2
						114 text Before you start
				115 text One document, the whole field. Read it in about an hour, or listen to the audio version. Everything here applies to Be Mindful's addiction and mental health day program at the partial hospitalization and intensive outpatient levels, paid mostly by Virginia Medicaid. Where a fact is still unconfirmed, the text says so.
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				117 button Play from How to use this
					118 heading How to use this, Value: 2
						119 text How to use this
				120 text There are fourteen parts. Each part builds on the one before, and nothing is repeated. Part One is the whole picture in five minutes. If you only have five minutes, listen to that. Numbers and deadlines you'll want to look up later are collected in the cheat sheet at the end of the written version.
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				122 button Play from The whole thing in five minutes
					123 text PART ONE
					124 heading The whole thing in five minutes, Value: 2
						125 text The whole thing in five minutes
				126 text A day program treats people who need more than a weekly therapy session but don't need a hospital bed. Two levels matter here. Intensive outpatient, called IOP, is a few hours a day, several days a week. Partial hospitalization, called PHP, is most of the day, five days a week. The client goes home every night.
				127 text Most clients are on Medicaid. In Virginia, Medicaid is run by the Department of Medical Assistance Services, called DMAS, but most members are enrolled in a private health plan called a managed care organization, or MCO. The program bills the plan, and the plan pays a flat daily rate, called a per diem, for each day of treatment it approved. To give you scale: Virginia's own fee schedule from 2022 shows about two hundred fifty dollars a day for addiction IOP and about five hundred dollars a day for addiction PHP. Plans negotiate their own rates, but that's the ballpark. Thirty billed days of PHP is roughly fifteen thousand dollars.
				128 text Here is the one idea that ties everything together. Compliance in this business is one question asked by many different people: can you prove the right client got the right level of care, from qualified staff, documented correctly, and billed correctly?
				129 text That question breaks into five proofs. First, the program is licensed and enrolled for that exact service at that exact location. Second, the client qualified for that level of care, which is called medical necessity, and the plan approved it in advance, which is called authorization. Third, the program actually delivered the required hours and services, with properly credentialed staff. Fourth, every day of care is documented in writing, individually, on time, and signed. Fifth, the bill matches the documentation exactly.
				130 text Every job in compliance is one of those five proofs, shown to someone who can take money back. The plan can take money back. The state can take money back. The federal government can take money back and, in serious cases, prosecute. The state licensing agency can restrict the program. That's the whole game. Everything else in this briefing is detail on those five proofs.
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				132 button Play from Who's who, and who makes the rules
					133 text PART TWO
					134 heading Who's who, and who makes the rules, Value: 2
						135 text Who's who, and who makes the rules
				136 text Start with the people. The client is also called the member, which is the insurer's word. The provider is the program. The payer is the health plan, or for the smaller fee-for-service population, the state itself through a contractor called Acentra Health, formerly KePRO, which handles authorizations in a system called Atrezzo. Since August 2026, providers reach Atrezzo through the DMAS provider portal.
				137 text Virginia's Medicaid managed care program is called Cardinal Care. Its health plans, as of the state's July 2025 forms, are Aetna Better Health of Virginia, Anthem HealthKeepers Plus, Humana Healthy Horizons in Virginia, Sentara Community Plan, and UnitedHealthcare. Humana took over the former Molina members in July 2025. Which of these plans BMOS is actually contracted with is the first question to ask the CEO.
				138 text Three state agencies matter. DMAS writes the Medicaid manuals, oversees the plans, audits providers, and runs the appeals process. The Department of Behavioral Health and Developmental Services, called DBHDS, licenses each service at each location and inspects. The Department of Health Professions licenses the individual clinicians.
				139 text At the federal level, the HHS Office of Inspector General audits Medicaid and keeps the list of people excluded from federal health programs. The Office for Civil Rights enforces privacy. And the Virginia Attorney General runs the Medicaid Fraud Control Unit, which investigates fraud and can walk in and take records.
				140 text Now the rules. There are seven layers, from highest to lowest. One, federal law and regulation. Two, Virginia law and regulation. Three, the DMAS provider manuals and forms. Four, each health plan's signed contract and provider manual. Five, the clinical criteria the plan uses to judge medical necessity. Six, accreditation standards, if the program is accredited. Seven, the program's own written policies.
				141 text Two things about these layers matter more than anything else. First, every layer binds you. A plan's contract can require more than the state requires, and once you sign it, you're bound for that plan's members. Your own policies bind you too, because auditors hold you to what you wrote down. Second, when you hear "that's not required," the expert's next question is always: not required by which layer? "Medicaid doesn't require it" only wins if every layer is silent, including the plan's contract and your own policy. Remember that question. It will save you more than once.
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				143 button Play from The two programs
					144 text PART THREE
					145 heading The two programs, Value: 2
						146 text The two programs
				147 text There are two tracks that look identical from the outside but run on different rulebooks. The addiction track is called ARTS, which stands for Addiction and Recovery Treatment Services. It's Virginia Medicaid's substance use benefit, and it uses the ASAM Criteria. The mental health track is a separate set of Medicaid services with criteria DMAS writes itself. A client goes to one track or the other based on the main problem. If the main problem is substance use, the mental health rules send the client to ARTS. You can't bill both at the same time, except for a short overlap during a transition.
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					149 text The ASAM Criteria.
					150 text  ASAM is the American Society of Addiction Medicine. Its Criteria are the national standard for deciding how much addiction care someone needs. The levels run from outpatient at Level 1, through Level 2.1, which is IOP, and Level 2.5, which is PHP, up through residential at the 3 levels and inpatient at Level 4.
				151 text The heart of ASAM is six dimensions, six lenses a clinician uses to judge severity. Virginia still uses the third edition from 2013, so learn these names. Dimension one, intoxication and withdrawal potential. Dimension two, biomedical conditions. Dimension three, emotional, behavioral, or cognitive conditions. Dimension four, readiness to change. Dimension five, relapse or continued-use potential. Dimension six, the recovery or living environment.
				152 text The fourth edition came out in 2023 and renamed things. Level 2.5 became "high-intensity outpatient." Dimension three became psychiatric and cognitive conditions. Dimension four became substance use-related risks. Dimension five became recovery environment interactions. Dimension six became person-centered considerations. Virginia's manual, revised in July 2025, and its authorization forms still use the third edition. If a reviewer quotes fourth-edition language at you, ask which edition they're applying.
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					154 text Level 2.1, addiction IOP.
					155 text  At least three hours a day for adults, averaging nine to nineteen hours a week. For adolescents, at least two hours a day, averaging six to nineteen. It's billed as one unit per day under code H0015, and no more than an average of nineteen hours a week can be billed.
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					157 text Level 2.5, addiction PHP.
					158 text  At least twenty hours a week, with at least five hours each day. Billed as one unit per day under code S0201.
				159 text For both levels, if a client misses the daily minimum, you document why and you tell the plan every week. If a client keeps missing, you reassess the level of care. A short step-down at reduced hours, one to two weeks, is allowed before moving to a lower level, but only if the plan approves it and the treatment plan supports it. Time that isn't skilled clinical treatment, like travel or downtime, isn't billable. Groups are capped at twelve people unless a credentialed clinician documents a reason to go bigger.
				160 text What each program must offer: individualized treatment planning; individual, group, and family counseling; medication management; education about the illness; skill building; access to psychiatric and medical consultation, within twenty-four hours by phone for IOP and within eight hours by phone for PHP; around-the-clock emergency coverage; screening for HIV, hepatitis, and tuberculosis if none was done in the past year; and access to addiction medications for opioid and alcohol use disorder, meaning buprenorphine, methadone, or naltrexone. PHP adds daily therapy and formal agreements with psychiatric and medical providers.
				161 text The staff who can do this work are called CATPs, which stands for credentialed addiction treatment professionals. That category includes licensed professional counselors, licensed clinical social workers, licensed marriage and family therapists, clinical psychologists, psychiatric nurse practitioners, addiction-credentialed physicians, licensed substance abuse treatment practitioners, and certain supervised residents. Certified substance abuse counselors, called CSACs, can run groups and do some assessments within their scope, with a CATP signing off where required.
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					163 text The mental health track.
					164 text  Mental health IOP is billed under code S9480 and mental health PHP under H0035. The rules are in the Mental Health Services manual, Appendix F, revised in May 2025. Mental health IOP must be available nine to nineteen hours a week for adults on at least three days, the client must get at least two distinct services a day and at least two hours of therapy a week, and you can bill at most five days a week. Mental health PHP runs at least four hours a day, five days a week, at least twenty hours total, with at least three distinct services each day and daily therapy.
				165 text Two clocks are specific to mental health. A psychiatric evaluation is due within seventy-two hours of admission for IOP and within forty-eight hours for PHP. Medication management is at least monthly for IOP and at least weekly for PHP. Treatment plans are reviewed every thirty days, and the assessment is updated every ninety.
				166 text To qualify for mental health PHP, the client needs a diagnosis expected to respond to treatment, worsening symptoms in the last fourteen days that hurt their functioning, risk of hospitalization without being an immediate danger, natural supports who can keep them safe outside program hours, a need for an intensive structured program with psychiatric involvement, and the ability to attend reliably. IOP is similar, with a thirty-day window. To continue in either, the client must still need this level and must be expected to respond, and the record must show progress or a changed plan, a psychiatric evaluation that considered medication, involvement of family or supports, and discharge planning from day one. If they no longer qualify, the plan can still approve up to ten more days to transition safely.
				167 text One more requirement for the mental health programs: they must be either Medicare-certified or accredited by CARF, the Joint Commission, the Council on Accreditation, or DNV. New programs get one year to certify or two years to accredit.
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				169 button Play from A client's path, and every clock on it
					170 text PART FOUR
					171 heading A client's path, and every clock on it, Value: 2
						172 text A client's path, and every clock on it
				173 text Walk one addiction client through the program. Every compliance requirement is a box on this path, and the clocks are what trip programs up.
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					175 text Assessment.
					176 text  It starts with a multidimensional assessment, face to face or by telehealth, done by a CATP, or by a CSAC with a CATP signing off. It must cover the full history, current symptoms, a mental status exam, the six dimensions, a diagnosis, and recommendations. Services have to start within thirty days of that assessment, or it must be redone.
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					178 text Initial authorization.
					179 text  The program submits a request on the state's form. Virginia recommends submitting no later than one business day after services start and no earlier than five days before. The form asks for the diagnosis codes, the client's addiction treatment history over the past year, medications, the level and number of days requested, and for each of the six dimensions a rating plus a summary with attachments. For opioid use disorder, the signature also attests that the client was told medication is the standard of care and has access to it.
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					181 text The plan's decision.
					182 text  For ARTS IOP and PHP, the plan must respond within seventy-two hours. The plan uses a licensed reviewer, called an ARTS Care Coordinator, or a physician, to do an independent assessment. If approved, the plan can pay back to the start date. If the plan simply doesn't decide in time, federal rules treat that as a denial.
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					184 text Treatment plan.
					185 text  The initial individual service plan, called the ISP, is due within twenty-four hours of admission. The comprehensive ISP is due within thirty days, even if the client leaves earlier. A separate interdisciplinary plan of care applies only to office-based and opioid treatment programs, not to IOP or PHP. Plans need measurable goals, the services and how often, target dates, a discharge plan, the clinician's signature, and the client's signature or a note on why they couldn't sign. You also need written proof the client was offered a choice of provider.
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					187 text Every day.
					188 text  Every billed day needs a progress note written that day or within one business day, signed and dated with credentials. More on what a good note looks like in Part Eight.
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					190 text Every week.
					191 text  If the client missed the daily minimum, tell the plan.
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					193 text The extension.
					194 text  This is the most expensive clock in the building. Before the current authorization ends, the program must ask for more days on the state's extension form. It can't go in more than five days early. If it goes in after the authorization has ended, the new approval starts on the day the plan receives it, not the day you needed it, and the days in the gap are usually unpaid. The extension form asks for the last three drug screens, all medications and how the client responded, the six dimensions again, how the client is progressing, revised goals, and a full discharge plan naming the next level of care and the receiving provider.
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					196 text Discharge.
					197 text  Discharge when a lower level would work, when the client asks, when they stop participating, or when they need a higher level. The discharge plan must show realistic continuity of addiction medication with an in-network provider. If there's no contact for thirty-one days in a row, the program must discharge. If the client comes back after more than ten days away, reassess.
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					199 text After.
					200 text  Claims must be submitted within twelve months of service under federal rules, and plan contracts can be shorter. Records are kept at least five years after service or discharge.
				201 text Mental health clients follow the same shape with their own clocks: the authorization request within one business day of admission, the continued-stay request by the requested start date (late means it starts on receipt), the forty-eight- or seventy-two-hour psychiatric evaluation, thirty-day plan reviews, and ninety-day reassessments.
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				203 button Play from Medical necessity and utilization review: how approvals are actually won
					204 text PART FIVE
					205 heading Medical necessity and utilization review: how approvals are actually won, Value: 2
						206 text Medical necessity and utilization review: how approvals are actually won
				207 text Medical necessity isn't the diagnosis. It's the documented match between the client's current condition and the written criteria for that level of care. Reviewers hold your chart up to a checklist. If the checklist isn't visibly satisfied in the chart, you lose, even if the client truly needs care.
				208 text Utilization review is the back-and-forth with the plan. There's the initial review for admission, and then concurrent reviews, also called continued-stay reviews, each time an authorization period runs out. Some plans review on the phone and some electronically, through portals or faxed forms. On the phone, the person on the other end is usually a licensed social worker, counselor, or nurse, and calls are often recorded. In behavioral health there are few reviewers, so your coordinators will talk to the same people again and again. Relationships matter.
				209 text Here's what wins reviews, drawn from experienced utilization reviewers.
				210 text Give facts from the chart, never opinion. Everything you say must be documented, because the plan can pull the records later, and an authorization is never a guarantee of payment. If the documentation doesn't match what was said on the call, the plan can take the money back after the fact.
				211 text Separate the diagnosis from the presenting problem. "Major depression" or "opioid use disorder" is the diagnosis. The presenting problem is why they need this level now: suicidal thoughts this week, a relapse after three weeks of sobriety, crying spells, not sleeping, losing a job. Reviewers ask for the presenting problem.
				212 text Use numbers. Standard rating scales, like the PHQ-9 for depression, tracked over time, persuade reviewers more than "client appears depressed."
				213 text Show active treatment. Medication changes, new interventions, a revised treatment plan. These show the program is working the problem, not just housing the client.
				214 text Track attendance. If the client isn't coming, the plan won't keep paying. If there's a real reason, like a hospital stay or a car accident, document it and ask the reviewer to extend the unused days.
				215 text Give an estimated length of stay, and keep the discharge plan realistic and current from day one. A discharge plan to a place the client can't actually manage, or with no way to get to appointments, isn't a plan. Include a crisis plan with real names and numbers.
				216 text Organize everything by the six dimensions, using the state form's own language. For PHP, the state form describes dimension three as symptoms that need to be stabilized, dimensions four and five as needing treatment almost daily and not responding to a lower level, and dimension six as an unsupportive environment where the client can still find outside support. When your evidence lines up with those words, you're speaking the reviewer's language.
				217 text To keep a client at the current level, ASAM's continued-stay test, which Virginia's manual quotes, has three doors. One, the client is making progress but hasn't reached their goals and needs this level to keep going. Two, the client isn't progressing yet but has the capacity to, and is actively working the plan. Three, new problems came up that this level is the least intensive place to treat. Document readiness for discharge or the need to continue, dimension by dimension. The mirror image is the discharge test: goals met, unable to resolve the problem despite plan changes, lack of capacity so another level is needed, or worsening so a higher level is needed. If the chart reads like the discharge test, be honest about it and plan the step-down. A weak fight wastes time, and the documentation gap you find is itself something to fix.
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					219 text Peer-to-peer.
					220 text  When a reviewer won't approve, ask for a peer-to-peer, a call between your physician or clinician and the plan's physician reviewer, who has the authority to overturn. It's often the fastest way to reverse a denial, but each plan sets its own window, so find out fast. Run the call like this. Identify the client, the level, and the dates. Ask which criterion the reviewer is applying, and which edition. State your position in one sentence. Give two or three dated facts per dimension, strongest first. Say what's likely to happen if care stops, with facts from the chart. Make a specific ask: this level, this many days. Offer a planned step-down, which shows good faith. Ask what evidence would change their mind. Get the outcome in writing. If the call fails, the formal appeal clock is already running.
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				222 button Play from Denials and appeals: the five tracks
					223 text PART SIX
					224 heading Denials and appeals: the five tracks, Value: 2
						225 text Denials and appeals: the five tracks
				226 text A denial is formally called an adverse benefit determination. The word "appeal" means different things depending on who is complaining, about what, and when. Mixing them up is how good cases die, so learn the five tracks.
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					228 text Track A, the member's appeal.
					229 text  This covers care the client is getting or about to get: a denied admission, a denied extension, a cut in days. Legally it's the client's appeal, and the program can file it only with the client's written consent. The client has sixty days from the date on the denial notice to file with the plan. There's one level of internal appeal. The plan must decide within thirty days, which can be extended fourteen, or within seventy-two hours if it's expedited because waiting would seriously jeopardize the client's health. If the plan loses or misses its deadline, the next step is a State Fair Hearing at the DMAS Appeals Division. In Virginia, the client has one hundred twenty days from receiving the plan's decision to request it. At the state level, DMAS doesn't rely on the plan's internal record, and its decision binds the plan.
				230 text The denial letter has to give specific reasons, and the client has the right to free copies of the records and the medical necessity criteria the plan used. Request them immediately.
				231 text Then there's continuation of benefits, which people get wrong. Federal rules let services continue during an appeal only when all of these are true: the appeal is about ending, suspending, or reducing services that were already authorized; the original authorization period hasn't expired; the appeal was filed on time; and the client asks for continuation within ten days of the notice, or by the date the change takes effect, whichever is later. A provider cannot request continuation. So if an extension is denied after the old authorization already ran out, continuation likely isn't available. That's an interpretation to confirm with DMAS or counsel. The lesson is simple: file extensions on time. That protects more money than winning appeals later.
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					233 text Track B, the provider's own appeal.
					234 text  This covers payment denied, or authorization denied, for services already delivered. First, the program must ask the plan for reconsideration. Each plan sets its own window, so check the provider manual. For fee-for-service members, the reconsideration goes to Acentra Health within thirty calendar days of the decision letter. Anthem, for example, gives twelve months from the payment notice for a claim reconsideration. If that fails, the program appeals to the DMAS Appeals Division. The deadline is thirty days from receiving the decision, with no extensions. It counts as filed only when DMAS date-stamps it, and anything arriving after five p.m. on the deadline day is late. It starts as an informal appeal, where you can request a meeting called an informal fact-finding conference within ninety days, and if you lose you can file a formal appeal within thirty days. The program carries the burden of proof. Collection of an audit overpayment is put on hold while an appeal is pending. One limit: providers can only appeal for services already delivered or being delivered, not for a purely future denial. That's what Track A is for.
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					236 text Track C, the audit response.
					237 text  Covered in Part Seven.
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					239 text Track D, the licensing corrective action plan.
					240 text  Covered in Part Ten.
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					242 text Track E, commercial insurance.
					243 text  If a client has private insurance, there's an internal appeal with the plan, and after that an external review by an independent reviewer. For fully insured Virginia plans, that's requested through the State Corporation Commission's Bureau of Insurance within one hundred twenty days. Self-funded employer plans follow federal rules instead.
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					245 text The common denial reasons, and the answers.
					246 text  "Not medically necessary, can be treated at a lower level": answer dimension by dimension with the state's own level language, and show any recent failure at a lower level. "The client has stabilized": usually negotiate a planned step-down unless the chart shows new problems. "No progress": use the second door of the continued-stay test, capacity and active work, and show the treatment plan was changed. "Not participating": show the reasons and your outreach, or accept a level change. "It's a social problem, not clinical": tie housing or family to relapse risk and symptoms. "Missing documentation": send exactly what the extension form lists. "Request was late": usually you won't win, so fix the process. "No medication plan for opioid use": document the education, the assessment, and access, then resubmit. And when the reason is vague, like "does not meet criteria," your first move is to demand the specific criterion and the edition.
				247 text When building an appeal letter: state the request and the timeline, the standard the plan must apply, the client's condition organized by dimension with page references, a point-by-point answer to each stated reason, the risk if care stops, and the clinician's signature. Two legal arguments sometimes apply, and they should go through counsel. First, federal law says a Medicaid plan's definition of medical necessity can't be more restrictive than the state's. Second, the parity law, covered in Part Twelve.
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				249 button Play from Audits: who shows up, what they check, and how to respond
					250 text PART SEVEN
					251 heading Audits: who shows up, what they check, and how to respond, Value: 2
						252 text Audits: who shows up, what they check, and how to respond
				253 text Auditors don't audit your program. They audit your paperwork. If it isn't written down, individualized, signed, and on time, it didn't happen.
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					255 text Who audits.
					256 text  The health plans audit their own members' care, through their utilization and special investigations units. DMAS and its contractors run utilization reviews and compliance reviews. Federal contractors also review Medicaid: recovery audit contractors look for overpayments in claims after payment, unified program integrity contractors investigate fraud, and a program called PERM measures national error rates. DBHDS inspects every licensed service at least once a year, unannounced. Accreditors survey on their cycle. And the Medicaid Fraud Control Unit and the Inspector General handle suspected fraud.
				257 container p-8-2
					258 text The two kinds of plan audit.
					259 text  A post-payment review is routine. The plan asks for a sample of charts and scores them. Experienced billers say to expect one from each major plan every few years. A prepayment review is the dangerous one. The plan stops paying, requires every claim to come in with its chart attached, and scores you until you pass. Backlogs can stretch for months, and the program still has to keep admitting clients to get out of it. That can sink a small program.
				260 container p-8-3
					261 text What triggers audits.
					262 text  Sudden jumps in census or billing volume, abrupt changes in coding, everyone carrying the same generic diagnosis, billing outpatient therapy on top of IOP or PHP for the same days, a switch in revenue codes, and patterns that look different from similar providers. Payers now use analytics, and increasingly AI, to review every chart, not just a sample.
				263 container p-8-4
					264 text What Virginia tells its reviewers to check.
					265 text  This is effectively the exam. Reviews can be desk audits or unannounced on-site visits with tours, staff interviews, and client interviews. They pull a sample of claims and expand the review if they find too many problems. They check that the license and the Medicaid enrollment list each service and each location, because anything unlisted can be taken back. That staff were screened against the federal exclusion list. That the admission and level of care were appropriate and the service was medically necessary. That the assessment was done by the right credential. That staff were qualified and staffing met the licensing rules. That services match the treatment plan, the invoices, and the limits. That the authorization is on file and the chart backs up what you told the plan to get it. That documentation is individualized. The manual says checklists, boilerplate, and repeated language aren't appropriate, and warns that electronic record systems offer canned language. That every required service component was delivered, with no duplicate services. That the billed amount matches the documented time. And that the client's primary care provider was informed, with consent forms that meet the federal addiction-privacy rule.
				266 container p-8-5
					267 text The money.
					268 text  Providers must refund payments billed against the rules, unsupported by documentation, or for care that wasn't medically necessary. Some payers extrapolate, which means they apply the error rate from the sample to a larger set of claims. Repeated problems can lead to the plan or DMAS restricting or ending the program's participation.
				269 container p-8-6
					270 text How to respond.
					271 text  First, contact the reviewer, acknowledge receipt, and for a records request, ask for more time if you need it. Then work the deadlines. In Virginia, after a review you get a written preliminary findings report, and you have thirty days from receiving it to respond with documentation that was written at the time of service. A final report follows. If a plan of correction is requested, you have thirty days to submit it. If you disagree, request the plan's reconsideration, and then appeal to DMAS within thirty days of the final decision, same rules as Track B.
				272 text For each finding, ask one question: is this actually required of us, by whom, and can we prove we met it? Trace it through all seven layers. If it's required and you met it, prove it with exhibits. If it's required and you didn't, write a corrective action plan, and if money was paid wrongly, talk to counsel about refunds. If you can't find the requirement in any layer, politely ask the auditor to identify the specific contract provision, manual section, or published policy, and its effective date.
				273 container p-8-8
					274 text The physicals example, worked properly.
					275 text  An auditor says clients don't have a physical exam on file. Here's what the layers actually show. In the federal rules reviewed, there's no blanket requirement. In the state licensing rules for Levels 2.1 and 2.5, there's no physical exam requirement. PHP must provide medical and nursing services as deemed appropriate in the assessment and plan. In the DMAS manual, a physician physical within twenty-four hours is required at Level 3.7, which is a residential level, not 2.1 or 2.5. At Level 1, the rule is to consult a physician to decide if an exam is needed when withdrawal or medical concerns show up. At 2.1 and 2.5, medical services are available by consultation or referral. But the manual's definition of the multidimensional assessment lists "physical examination" as an element, and the documentation chapter says "information available from current physical examination." An auditor could lean on that wording. And the plan's contract and BMOS's own policies haven't been reviewed yet. So the honest answer today is: not clearly required by Medicaid at this level, but unverified until the plan contract and BMOS policy are checked. Don't argue the finding is invalid until every layer has been searched. That one example is the whole method.
				276 container p-8-9
					277 text Getting out of a prepayment review.
					278 text  Experienced billers say the fastest exits often come from the regulatory side, not from sending more charts. That means reading the plan contract, the state's rules for that license, and the state insurance or managed care regulations, and showing where the plan is out of bounds. One example from the field: a plan was withholding payment over missing admission paperwork that had nothing to do with medical necessity, and a well-documented complaint copied to the state regulator got the review lifted within two weeks. Outcomes data, showing clients do well after discharge, also helps in both audits and rate negotiations.
				279 container p-8-10
					280 text Prevention.
					281 text  Turn every finding into a checklist item, and run mock audits using the state's own checklist above, before anyone else does.
			282 container part-9
				283 button Play from Documentation that survives an audit
					284 text PART EIGHT
					285 heading Documentation that survives an audit, Value: 2
						286 text Documentation that survives an audit
				287 text The assessment must include every required element: history of the present illness, family, developmental, substance use, social, legal, psychiatric, and medical history, a review of systems, a mental status exam, available physical exam information, a diagnosis, and recommendations. It must be updated when the client's needs change or the level changes.
				288 text The treatment plan must be individualized and current, with measurable goals and dates, specific interventions, the frequency of services, the discharge plan, and signatures. It must be redone for each new episode of care. You can't reuse an old plan.
				289 text The golden thread is what auditors look for: assessment, then treatment plan, then the services delivered, then the progress notes, all clearly connected. If the plan says the client goes to group therapy to build coping skills, the notes must show the group, what was done, and how the client responded.
				290 text Every progress note needs the name of the service, the date, the time or units, the setting, the specific interventions staff used, the client's response and progress or lack of progress toward the plan's goals, and the author's signature, date, and credentials, written the same day or within one business day. Virginia won't pay for a day whose note isn't individualized and specific to that client. Duplicated notes don't count. Even if a therapist always uses the same technique, the discussion must be specific to that client that day.
				291 text Watch for these traps. Don't bill before the note is written and signed. Don't let the person on the claim differ from the person who did the work, and make sure that person is credentialed with that plan. Supervisees and pre-licensed clinicians follow plan-specific rules. Late notes are a compliance problem for leadership to fix, not something billing can work around. For telehealth, the note must say whether it was audio and video or audio only, and where the client was. Mental health telehealth requests to the plan must include the telehealth schedule and the clinical reason telehealth is appropriate. Separate distinct services in the note, such as psychotherapy versus a medication visit. And code diagnoses specifically. Complications and secondary diagnoses that are really present belong on the claim, because generic codes for everyone look suspicious.
			292 container part-10
				293 button Play from Getting paid correctly
					294 text PART NINE
					295 heading Getting paid correctly, Value: 2
						296 text Getting paid correctly
				297 text The billing chain must reconcile end to end: attendance, then documented hours, then units, then a valid authorization covering that date, then the claim. In Virginia, partial units aren't rounded up. Bill whole units only, and the billed time must match the documented time. Don't bill a per diem for a day the client wasn't there. Addiction IOP is H0015, revenue code 0906 on a facility claim. Addiction PHP is S0201, revenue code 0913. Mental health IOP is S9480, and mental health PHP is H0035, one per day. You must be credentialed with the client's plan to bill it.
				298 text Drug testing is a classic risk area. Testing should be ordered on individual medical necessity, not every client at every visit. Screening tests are billed with presumptive codes and confirmation tests with definitive codes, generally one of each per day, and plans set frequency limits. Blanket testing has produced major fraud settlements, and a family on one of the training panels described a Florida program doing exactly that. The extension form asks for the last three drug screens, so testing should be purposeful and documented.
				299 text Eligibility checks matter more than ever. Check at intake and on a schedule. Clients switch plans. Starting in January 2027, Virginia adds a federal work requirement for many Medicaid expansion adults ages nineteen to sixty-four: eighty hours a month of work, training, volunteering, or half-time school, or about five hundred eighty dollars a month in income, unless they're exempt. People with substance use disorders and serious mental health conditions are among the exempt groups, but exemptions still have to be established. Those same adults get coverage reviews every six months instead of twelve, and retroactive coverage gets more limited. Expect more coverage gaps. Any disclosure of addiction treatment to support an exemption needs proper consent.
				300 text For commercial clients, verify benefits before admission: active coverage, in-network or out, deductibles, copays, prior authorization rules, and behavioral health limits. If the program is out of network, a single case agreement can set in-network rates for one client, but only if signed before services start. Patient cost-sharing must be collected or discounted under a written, documented hardship policy, because routinely waiving it is a compliance problem.
			301 container part-11
				302 button Play from Licenses, enrollment, people, and incidents
					303 text PART TEN
					304 heading Licenses, enrollment, people, and incidents, Value: 2
						305 text Licenses, enrollment, people, and incidents
				306 container p-11-0
					307 text Licensing.
					308 text  DBHDS licenses each service at each location. Addiction IOP and PHP, and mental health IOP and PHP, are separate licensed services. Expect at least one unannounced inspection of each service every year. After a licensing report, the corrective action plan is due in fifteen business days, with one extension of up to ten business days if requested before the deadline. It must describe the fix, the completion date, and the responsible person. If DBHDS rejects it, you get ten more business days. Repeated violations, threats to health and safety, or failure to follow a prior plan can lead to a provisional license, and Medicaid doesn't pay programs on a provisional license.
				309 container p-11-1
					310 text Enrollment and credentialing.
					311 text  Licensing isn't enrollment. Every service and location must also be enrolled with DMAS through its provider enrollment vendor and contracted and credentialed with each plan. Plans can't contract with providers who aren't enrolled with DMAS. Credentialing packets include the DBHDS license, site survey, insurance certificates, business license, ownership disclosure, and accreditation if requested. Enrollment must be revalidated at least every five years. A service or location that's missing from the enrollment can have all its payments taken back.
				312 container p-11-2
					313 text Exclusion screening.
					314 text  Every employee and contractor must be checked against the federal exclusion list at hire and every month, and against the federal SAM exclusion list too. Keep the evidence. Report any hit to DMAS immediately. Paying for services by an excluded person creates repayment liability and penalties.
				315 container p-11-3
					316 text Staff credentials.
					317 text  Track every license and certification and its expiration. Make sure each service was delivered by someone allowed to deliver it, and that supervisees are supervised and co-signed where required. Therapy notes by residents need a licensed clinician's co-signature, while group notes and activities don't.
				318 container p-11-4
					319 text Serious incidents.
					320 text  Level two and level three serious incidents must be reported to DBHDS within twenty-four hours of discovery, and a root cause analysis is due within thirty days.
				321 container p-11-5
					322 text Human rights complaints.
					323 text  Virginia's human rights rules require the program to notify DBHDS of a client complaint no later than the next business day, have the director contact the client within twenty-four hours, start an impartial investigation by the next business day, protect the client from retaliation, give access to a human rights advocate, and deliver a written decision and action plan within ten working days with notice of appeal rights. Abuse or neglect allegations must be reported within twenty-four hours. Complaint policies must be in writing and approved by DBHDS.
				324 container p-11-6
					325 text Accreditation.
					326 text  CARF and the Joint Commission are the big two. CARF surveys are scheduled, two to three days on site, and result in a three-year accreditation, a one-year accreditation, or none. Getting ready usually takes nine to eighteen months, largely to build outcomes measurement. In Virginia, mental health IOP and PHP require accreditation unless the program is Medicare-certified.
				327 container p-11-7
					328 text Policies.
					329 text  Every rule above should be backed by a written policy that matches what staff actually do, reviewed on a schedule, and updated when rules change.
			330 container part-12
				331 button Play from Privacy: HIPAA, and the stricter addiction-records rule
					332 text PART ELEVEN
					333 heading Privacy: HIPAA, and the stricter addiction-records rule, Value: 2
						334 text Privacy: HIPAA, and the stricter addiction-records rule
				335 container p-12-0
					336 text HIPAA
					337 text  is the general health privacy law. Any vendor that touches patient information for you must sign a business associate agreement, called a BAA. Use and share only the minimum necessary. Patients can access their records. If unsecured patient information is breached, affected people must be notified without unreasonable delay and within sixty days of discovery, and HHS must be notified on a schedule that depends on whether more than five hundred people were affected.
				338 container p-12-1
					339 text 42 CFR Part 2
					340 text  is the federal rule for substance use disorder treatment records, and it's stricter. It covers records that identify someone as having a substance use disorder, held by a federally assisted program. That includes Medicare participants and recipients of federal financial assistance, and Medicaid-funded programs are generally treated as covered. Confirm BMOS's status with counsel. The core protection is that these records can't be used against the patient in criminal, civil, administrative, or legislative proceedings without the patient's consent or a court order.
				341 text The 2024 update brought Part 2 closer to HIPAA, and compliance was required by February 16, 2026. A patient can now sign one consent covering all future uses for treatment, payment, and health care operations. Recipients that are HIPAA-covered can then redisclose under HIPAA rules, but still not to use against the patient. Every disclosure made with consent must carry a specific redisclosure notice. Separate counseling notes, kept apart from the main record, need their own specific consent. Breaches of Part 2 records now follow HIPAA's breach notification rules, and enforcement now follows HIPAA's penalty framework.
				342 text A vendor that serves a Part 2 program also needs a written qualified service organization agreement, called a QSOA, saying it is bound by Part 2. A standard AI vendor's BAA doesn't mention Part 2. Get that language in writing.
				343 text In practice, before any record leaves the building, whether for an appeal, an audit, the client's primary care provider, or an exemption request, check that the consent is valid and covers that recipient and purpose, attach the notice, send only what's needed, and log the disclosure. Virginia also requires the program to inform the client's primary care provider of treatment, with proper consent, and to send a discharge summary to the primary care provider and any case manager.
				344 text For the AI tool, the rule is simple: no real client information goes into any AI system that isn't covered by both a BAA and a QSOA. Build and test with made-up cases.
			345 container part-13
				346 button Play from The legal lines you never cross
					347 text PART TWELVE
					348 heading The legal lines you never cross, Value: 2
						349 text The legal lines you never cross
				350 container p-13-0
					351 text The False Claims Act.
					352 text  Billing for what you know, or recklessly ignore, is false, including claims your documentation doesn't support, can mean three times the damages plus a penalty per claim, about fourteen thousand to twenty-eight thousand dollars each after the 2025 adjustment. Whistleblowers, often former employees, can bring these cases.
				353 container p-13-1
					354 text Overpayments.
					355 text  Once you identify an overpayment, you have sixty days to report and return it. Since January 2025, "identified" means you know about it or are recklessly ignoring it, and you get up to one hundred eighty days to investigate related overpayments in good faith before the sixty days run. Keeping an identified overpayment can itself become a false claim. When an audit or your own review shows you were wrong, call counsel. Don't argue it away.
				356 container p-13-2
					357 text Kickbacks and patient brokering.
					358 text  The federal anti-kickback law covers federal health programs, and the Eliminating Kickbacks in Recovery Act, called EKRA, makes it a crime to pay or receive anything of value for referring patients to a treatment program, recovery home, or lab, no matter who pays for the care. Marketing deals, "outreach" payments, free housing tied to admission, and payments to referral sources are where programs get hurt. Counsel reviews every such arrangement.
				359 container p-13-3
					360 text Exclusions.
					361 text  Covered in Part Ten. Never bill for work done by an excluded person.
				362 container p-13-4
					363 text Drug testing and upcoding.
					364 text  Blanket testing, billing more units than documented, and billing services not delivered are the classic fraud patterns in this industry.
			365 container part-14
				366 button Play from Leverage: parity and the plan's own rules
					367 text PART THIRTEEN
					368 heading Leverage: parity and the plan's own rules, Value: 2
						369 text Leverage: parity and the plan's own rules
				370 container p-14-0
					371 text Parity.
					372 text  The Mental Health Parity and Addiction Equity Act says a plan's limits on mental health and addiction care can't be stricter than its limits on comparable medical care. Quantitative limits are numbers, like copays and visit caps. Non-quantitative limits are the sneakier ones, like stricter prior authorization, more frequent record requests, narrower networks, or harsher medical necessity criteria for behavioral health than for comparable medical services. The 2008 law and its 2013 rules are in force. A stronger 2024 rule is under a federal non-enforcement pause while it's litigated. Parity applies to commercial plans and to Medicaid managed care. It's an argument for counsel to decide when to use, not an automatic win.
				373 container p-14-1
					374 text The plan can't be stricter than the state.
					375 text  Federal Medicaid rules require a plan's definition of medical necessity to be no more restrictive than the state's. Denials must also be made by someone with the right expertise, so a non-clinician or a reviewer from an unrelated specialty is worth noting.
				376 container p-14-2
					377 text Generally accepted standards.
					378 text  In a long-running federal case called Wit versus United Behavioral Health, a court found an insurer's internal level-of-care guidelines were narrower than generally accepted standards of care, and as of early 2026 a court order requires that insurer to use criteria reflecting those standards. It's a commercial insurance case, persuasive background rather than binding in Virginia Medicaid.
			379 container part-15
				380 button Play from What's changing right now, and how to think like an expert
					381 text PART FOURTEEN
					382 heading What's changing right now, and how to think like an expert, Value: 2
						383 text What's changing right now, and how to think like an expert
				384 container p-15-0
					385 text What's changing.
					386 text  Virginia retired several legacy Medicaid behavioral health services on July 1, 2026, including mental health skill-building, psychosocial rehabilitation, intensive in-home, and therapeutic day treatment, and launched new services with new licenses. If BMOS offered skill-building, that line changed. Several manuals may have been reissued, so pull fresh copies. The 2024 Part 2 privacy rule became mandatory in February 2026. Since January 2026, Medicaid plans must decide standard authorization requests within seven days and give a specific reason for any denial. Virginia's addiction rule is faster still, at seventy-two hours. In January 2027, plans must offer electronic prior authorization connections, and Virginia's work requirement and six-month renewals begin. The ASAM fourth edition is spreading, but Virginia's manual still uses the third. The 2024 parity rule is paused. A major HIPAA security update requiring things like multi-factor authentication and encryption has been proposed but not finalized. And Virginia has debated, but not passed, limits on insurers using AI to make denials.
				387 container p-15-1
					388 text The twelve questions an expert asks of any program.
					389 text  One, are we licensed, enrolled, and contracted for every service at every location? Two, which plans do we bill, and what does each one's contract require beyond the state? Three, which criteria, and which ASAM edition, does each plan's reviewer use? Four, does every client have a valid authorization covering today? Five, are extension requests going in before expiry, every time? Six, does every chart show the golden thread, with notes written within one business day and individualized? Seven, do billed units match documented hours and attendance? Eight, is everyone credentialed, supervised, and screened against the exclusion list this month? Nine, do we have valid Part 2 consents before every disclosure? Ten, what are our denial rates and appeal win rates by plan and reason? Eleven, which audits are open, what did past audits find, and did we fix those findings? Twelve, which rules changed this year, and did our policies change with them?
				390 container p-15-2
					391 text How this connects to the system we're building.
					392 text  Every part of this briefing becomes a piece of the tool. The rule layers become the cited requirements library. The clocks become the deadline engine. Part Five becomes the authorization agent and the countdown board. Part Six becomes the appeals agent. Part Seven becomes the audit defense agent and the mock audits. Part Eight becomes chart quality checks. Part Nine becomes billing integrity and coverage checks. Part Ten becomes the workforce and licensing agents. Part Eleven becomes the consent guard. And Part Fourteen becomes the regulatory watch. The build plan lays that out in detail. With this briefing, you know what each of those pieces is protecting, and why.
				393 text That's everything. Come back to this whenever you need to refresh, and use the cheat sheet below for the numbers.
			394 heading The clocks and numbers, Value: 2
				395 text The clocks and numbers
			396 table
				397 row
					398 cell
						399 text WHAT
					400 cell
						401 text RULE
				402 row
					403 cell
						404 text Services start after assessment
					405 cell
						406 text within 30 days, or redo the assessment
				407 row
					408 cell
						409 text Initial ARTS authorization request
					410 cell
						411 text no later than 1 business day after start; not more than 5 days before
				412 row
					413 cell
						414 text Initial MH authorization request
					415 cell
						416 text within 1 business day of admission
				417 row
					418 cell
						419 text Plan decision, ARTS 2.1/2.5
					420 cell
						421 text 72 hours
				422 row
					423 cell
						424 text Federal outer limits for plan decisions
					425 cell
						426 text 7 days standard (since Jan 2026), 72 hours expedited, +14 days extension
				427 row
					428 cell
						429 text Initial ISP / comprehensive ISP
					430 cell
						431 text 24 hours / 30 days (a separate plan of care applies only to office-based and opioid treatment programs)
				432 row
					433 cell
						434 text MH psychiatric evaluation
					435 cell
						436 text 48 hours (PHP), 72 hours (IOP)
				437 row
					438 cell
						439 text MH plan review / reassessment
					440 cell
						441 text every 30 days / every 90 days
				442 row
					443 cell
						444 text Progress note
					445 cell
						446 text same day or within 1 business day
				447 row
					448 cell
						449 text Missed daily minimum (ARTS)
					450 cell
						451 text tell the plan weekly
				452 row
					453 cell
						454 text Extension request
					455 cell
						456 text before the authorization ends, not more than 5 days early; late = starts on receipt
				457 row
					458 cell
						459 text No contact
					460 cell
						461 text discharge after 31 days; reassess if gone more than 10 days
				462 row
					463 cell
						464 text Member appeal to the plan
					465 cell
						466 text 60 days from the date on the notice; consent required for provider to file
				467 row
					468 cell
						469 text Plan appeal decision
					470 cell
						471 text 30 days (+14) or 72 hours expedited
				472 row
					473 cell
						474 text Continuation of benefits
					475 cell
						476 text member asks within 10 days or by the effective date; only for cuts to unexpired authorizations
				477 row
					478 cell
						479 text State Fair Hearing (Virginia)
					480 cell
						481 text 120 days from receiving the plan's decision
				482 row
					483 cell
						484 text DMAS provider appeal
					485 cell
						486 text 30 days, no extensions, date-stamp rule, 5 p.m. cutoff; informal then formal
				487 row
					488 cell
						489 text Audit preliminary findings response / plan of correction
					490 cell
						491 text 30 days / 30 days
				492 row
					493 cell
						494 text Licensing corrective action plan
					495 cell
						496 text 15 business days (+10 if requested before due)
				497 row
					498 cell
						499 text Serious incident report / root cause analysis
					500 cell
						501 text 24 hours / 30 days
				502 row
					503 cell
						504 text Human rights complaint
					505 cell
						506 text DBHDS notice next business day; contact within 24 hours; decision within 10 working days
				507 row
					508 cell
						509 text Exclusion screening
					510 cell
						511 text at hire and monthly
				512 row
					513 cell
						514 text Enrollment revalidation
					515 cell
						516 text at least every 5 years
				517 row
					518 cell
						519 text Claim submission
					520 cell
						521 text within 12 months (plans may be shorter)
				522 row
					523 cell
						524 text Records retention
					525 cell
						526 text at least 5 years after service or discharge
				527 row
					528 cell
						529 text HIPAA breach notice to individuals
					530 cell
						531 text within 60 days of discovery
				532 row
					533 cell
						534 text Overpayment return
					535 cell
						536 text 60 days after identified; up to 180 days to investigate related ones
				537 row
					538 cell
						539 text Medicaid renewals for affected expansion adults
					540 cell
						541 text every 6 months starting January 2027
				542 row
					543 cell
						544 text Hours: ARTS 2.1 / 2.5
					545 cell
						546 text 3 hrs/day, 9-19 hrs/week (adults) / 5 hrs/day, 20+ hrs/week
				547 row
					548 cell
						549 text Hours: MH-IOP / MH-PHP
					550 cell
						551 text 9-19 hrs/week, 3+ days, max 5 units/week / 4 hrs/day, 5 days, 20+ hrs/week
				552 row
					553 cell
						554 text Codes
					555 cell
						556 text H0015 (2.1), S0201 (2.5), S9480 (MH-IOP), H0035 (MH-PHP); 1 unit = 1 day
				557 row
					558 cell
						559 text Group size (ARTS)
					560 cell
						561 text 12 maximum unless a CATP documents a reason
				562 row
					563 cell
						564 text 2022 FFS reference rates
					565 cell
						566 text about $250/day (2.1), $500/day (2.5)
			567 heading Where these facts come from, Value: 2
				568 text Where these facts come from
			569 container
				570 text Each part draws on the cited requirements library in  03_REQUIREMENTS_LIBRARY_SEED.md  (record IDs in parentheses) and its saved sources: Part One (A-042). Part Two (M-001, M-002). Part Three (A-001, A-015 to A-019, A-035 to A-038, A-041, C-001, L-001 to L-003). Part Four (A-010 to A-014, A-020 to A-023, A-032, A-034). Part Five (A-024, A-025, A-039) plus the practitioner training "Utilization Review for the Novice" (ICANotes). Part Six (F-004 to F-008, L-006, A-027 to A-029, X-003, M-003). Part Seven (A-026, A-027, F-018) plus "How to Survive a Payer Audit" (Delivering Recovery) and federal program-integrity summaries (MACPAC). Part Eight (A-021 to A-023) plus "Behavioral Health Q&A: Documentation, Billing, and Audit Risk". Part Nine (A-034, A-043; drug-testing billing from payer policies). Part Ten (L-004, L-005, L-007, A-030, A-031, A-041, X-001; DBHDS inspection frequency per 12VAC35-105-70 as summarized in search results). Part Eleven (F-010 to F-013, A-033). Part Twelve (F-016, F-017). Part Thirteen (F-001, F-002, F-014, X-002) plus "Addiction Treatment and Insurance Coverage Denials" (Partnership to End Addiction). Part Fourteen (A-040, A-043, F-003, F-015, X-004). Items marked as interpretations, or as general knowledge, should be confirmed with counsel or the agency before anyone relies on them in a filing.

The focused UI element is 1 AXWebArea Listen & Read · Mindful Compliance, URL: 127.0.0.1:8767/resource/#listen