How to build a family program for an IOP or PHP

Why it's worth building

Families shape the recovery environment the client goes home to every night, which is one of the dimensions reviewers weigh at every authorization. SAMHSA's TIP 39 on substance use disorder treatment and family therapy (revised 2020) lays out models for bringing families into treatment, and its companion advisory on the importance of family therapy summarizes what programs should consider. We run a licensed Texas outpatient program; this guide is how we set up family services when we build a client's clinical program in the IOP / PHP Program Launch, grounded in that evidence and the rules below.

The three parts of a family program

Part	What it is	Typical cadence	Who leads
Family sessions	Family therapy for one client's family: with the client (conjoint) or, when it helps, family members alone	Set in each client's plan, often every other week; more for adolescents	The primary counselor or a licensed family therapist
Family education group	Education and support for families of several clients, on a rotating topic list	Weekly, evenings, 90 minutes	A counselor; guest speakers for some topics
Family in planning	Family input into the treatment plan, step-downs and the discharge plan	At plan reviews and before discharge	The primary counselor

"Family" is whoever the client says it is: a partner, parent, adult child, close friend or sponsor. Ask on day one and write it down.

What Texas requires

For a licensed chemical dependency treatment facility under 26 TAC chapter 564:

Requirement	Rule	What it means in practice
Tell clients about family involvement	564.802(b)(16)	The consent to treatment covers opportunities for family involvement; describe your family sessions and group in it
The plan addresses family relationships	564.1 (treatment planning); 564.803(a)(5)	The assessment covers relationships with family; the plan addresses them where they're a problem or a strength
Family helps develop the plan when appropriate	564.804(a)	Invite family to a plan review, with consent
Family in discharge planning when appropriate	564.805(d)	A family session before the last week is a natural place to review the aftercare plan
Adolescents: involve family or document why not	564.905(d)(2)	Every adolescent chart shows family or an alternate support system involved, or a written reason
Co-occurring disorders: family education and support	564.909(b)–(c)	The plan names family members' need for education about both disorders and how you'll meet it
Multi-family events can exceed the group cap	564.901(b)	Education groups are capped at 35, except multi-family events

Rule texts: 564.802, 564.804, 564.905. Checked against the rule text in September 2026; confirm with HHSC before relying on it.

Consent and Part 2

If your program treats substance use disorders and is federally assisted (Medicare or Medicaid enrollment, a DEA registration or federal funds all count), 42 CFR Part 2 protects the records, on top of HIPAA. For a family program that means:

• Written consent before any disclosure to family, meeting every element of 42 CFR 2.31: who may disclose, what information, to whom (name each family member), why, how to revoke, an expiration date or event, the client's signature and the date.
• Even confirming someone is a client of a facility publicly identified as providing only substance use disorder care requires the client's written consent or a court order (42 CFR 2.13(c)). A general health facility may acknowledge a patient's presence only if it doesn't reveal a substance use disorder.
• Attending a family session is a disclosure. Get the consent before the first session, and scope it to what will be discussed.
• Minors: where state law lets the minor consent to treatment alone, only the minor signs releases, even to a parent (42 CFR 2.14). Texas's chapter 564 definitions say a 16- or 17-year-old may consent to their own treatment, so for that client, ask your attorney who signs a release to the parents.
• Revocation is real. If a client revokes consent mid-program, family contact stops, and the chart says when.

The 2024 Part 2 rule brought Part 2 closer to HIPAA, with a compliance date of February 16, 2026; update consent forms that predate it (the intake packet in our program launch uses the current Part 2 language). Cima EHR keeps Part 2 releases on each chart so staff can see, before they speak, who the client has allowed.

When family calls: a script

Front-desk staff and techs take these calls more than counselors do. Train everyone on the same words.

• Then check the chart for a release. If there's none, tell the client (if they are one) that someone called, and ask whether they want to sign one.
• Information can come in without consent: you can listen to what the family member wants to tell you. You just can't confirm anything back.
• In an emergency, follow your crisis procedure. Part 2 allows disclosure to medical personnel in a bona fide medical emergency (42 CFR 2.51); it isn't a general exception for family. Involve the clinical director and document the reason.

Family sessions

A 50-minute conjoint session that stays focused on the client's treatment:

1. Before: confirm the release names everyone attending. Agree with the client what they do and don't want discussed.
2. Open (5 min): purpose of the session, confidentiality and its limits, the goal from the client's plan this session serves.
3. Work (35 min): the topic the plan calls for: communication patterns, a relapse warning-sign plan the family can support, house rules after discharge, rebuilding trust, a boundary.
4. Close (10 min): one concrete step for each person before the next session.
5. Note: who attended (names and relationships), start and end times, the plan goal addressed, what was worked on, and the client's response. That's what supports billing and what a surveyor reads.

Family members alone (90846) can make sense when the family needs coaching the client shouldn't sit through, for example how to stop funding use or respond to a lapse. Approaches like Community Reinforcement and Family Training (CRAFT) teach families to encourage treatment and reward non-use instead of confrontation.

The family education group: an 8-week rotation

Weekly, 90 minutes, open to families of current clients (and, if you choose, recent graduates). Run it as an education and skills group with a written curriculum, like the client group curriculum, so a family can join any week.

Week	Topic	What families practice
1	Addiction as a health condition: what happens in the brain, and why "just stop" doesn't work	Naming what they've tried and how it went
2	How treatment works: levels of care, what PHP, IOP and outpatient look like, what happens after	Questions to ask the care team (with consent)
3	Helping versus enabling	Sorting real situations; one change to make this week
4	Communication that lowers conflict	I-statements and positive requests, role-played
5	Boundaries and consequences that hold	Writing one boundary and how they'll keep it
6	Lapse and relapse: warning signs, and what to do in the first hour	A family plan for a lapse
7	Overdose and medications: naloxone, and medications for opioid and alcohol use disorder	Naloxone demonstration; myths and facts
8	Taking care of yourself: Al-Anon, Nar-Anon, SMART Recovery Family & Friends, therapy for family members	Choosing one support for themselves

Keep the group about families' own questions and skills, not about any client's treatment. Members of different families shouldn't hear each other's relative's clinical details; that's another disclosure. Fit it on an evening that doesn't clash with the evening IOP schedule, or run it during evening IOP so clients' rides are already there.

Billing: 90846, 90847 and the per diem

Code	What it is	Billing notes
90847	Family psychotherapy (conjoint), with the client present	A time-based code (50 minutes in the descriptor); under CPT's time rules it's commonly reported once 26 minutes are spent. Confirm with each payer.
90846	Family psychotherapy without the client present	Same time rules. Payers generally expect the session to be for the treatment of the identified client, and some don't cover it at all.
90849	Multiple-family group psychotherapy	Psychotherapy for several families at once. A family education group is usually education, not psychotherapy, so don't bill it as 90849 unless it truly is therapy and the payer covers it.

• Per diem first. Most IOP and PHP contracts pay one daily rate (H0015, S9480, S0201 and the like). Whether a family session on a program day is inside that rate or billed separately is a contract question. Our EHR's default treats individual and family sessions on program days as part of the per diem unless the program bills them separately; set it to match each contract.
• Bill under the identified client, with the client's diagnosis, and document who attended and how the session addressed the client's plan goal.
• Licensure matters. Check which license types each payer pays for family therapy before you schedule it, especially for counselor interns and associates.

For the per diem codes and how claims work, see the code table in our guide to starting an IOP or PHP in Texas.

Measuring it

• Family participation: clients with at least one family session or a family member at the education group ÷ clients with a family member on a release.
• Adolescent compliance: adolescent charts with family involvement or a documented reason ÷ adolescent charts. Target 100%.
• Release coverage: family contacts that happened with a valid release on file. Target 100%; anything else is a privacy incident to report and fix.

These belong in the quarterly quality review, next to the outcomes in our discharge planning guide.

Questions

Is family therapy required in an IOP?

Not for every adult client. Texas requires licensed facilities to tell clients about opportunities for family involvement, involve family in planning and discharge when appropriate, and, for adolescents, involve family or another support system or document why it isn't possible (26 TAC 564.905(d)(2)).

What is the difference between 90846 and 90847?

90847 is family psychotherapy with the client present; 90846 is family psychotherapy without the client. Both are time-based codes, and payers generally expect the session to be for the treatment of the identified client.

Can we tell a parent that their adult son is in treatment?

Not without his written consent. Under 42 CFR Part 2, a facility publicly identified as providing only substance use disorder care can't even acknowledge that someone is a client without written consent or a court order (42 CFR 2.13(c)), and any other disclosure to family needs a written consent too. You can listen to the parent and tell them about your family group.

Who signs the release for a 16-year-old client in Texas?

Texas's chapter 564 definitions let 16- and 17-year-olds consent to their own treatment, and under 42 CFR 2.14, when a minor can consent alone, only the minor signs releases. Have your attorney confirm the Texas answer for your program.

Is a family education group billable?

Usually not as psychotherapy. Most programs offer it as part of the program. A true multiple-family therapy group may be billable as 90849 if the payer covers it and the documentation supports therapy.

Can family members attend the client's regular groups?

Generally no: other clients' confidentiality is at stake. Use a separate family group, and conjoint family sessions for one client's family.

Need your team trained on Part 2 and family calls? A live staff training session is $500 per session. Or book a free 30-minute call.

Cima Consulting isn't a law firm. Confidentiality and minor-consent questions depend on your facts; have your health-care attorney review your forms.

Sources

• SAMHSA, TIP 39, Substance Use Disorder Treatment and Family Therapy: store.samhsa.gov; Advisory based on TIP 39: library.samhsa.gov
• 42 CFR Part 2: eCFR; sections 2.13, 2.14, 2.31 (Cornell LII)
• 26 TAC chapter 564 (Cornell LII): chapter index, 564.802, 564.804, 564.905