How to start an IOP in Virginia: the DBHDS license, ARTS and the steps

Who wrote this, honestly

We're Texas operators: we run a licensed Texas outpatient program, PHP through outpatient, and built our own EHR to run it. When we help an owner open in another state, the first task on that client's roadmap is "apply for your state's SUD treatment program license", and the work behind it is finding the state's rule and checking it against the agency's current text. This guide is that check for Virginia, and it's the same work our IOP / PHP Program Launch does for a client opening outside Texas. Where we couldn't confirm a detail, we left it out or told you who to ask.

Comparing neighbors? Read our guides for North Carolina, Kentucky and Tennessee, or how to start an IOP or PHP in Texas.

Virginia at a glance

Question	Virginia's answer
Who licenses SUD programs	DBHDS Office of Licensing
Rule	12VAC35-105, Rules and Regulations for Licensing Providers by DBHDS; ASAM Level 2.1 in sections 1730 to 1770 (effective February 17, 2023)
IOP hours	At least 3 service hours per service day, 9 to 19 hours a week (12VAC35-105-1740); Medicaid allows 2 hours a day and 6 to 19 a week for children and adolescents
How you apply	The DBHDS CONNECT provider portal, with an attestation that your policies comply
Waitlist	Accepted applications join a waitlist; Priority 1, Priority 2 and Non-Priority services since July 30, 2025
First license	Usually conditional, up to six months, one service at a time (January 2026 memo)
Counselor credentials	Board of Counseling: LSATP, CSAC and CSAC-A, plus other licensed professionals
Medicaid	DMAS's ARTS benefit; Cardinal Care plans Aetna, Anthem HealthKeepers Plus, Humana, Sentara and UnitedHealthcare; Magellan of Virginia for fee-for-service behavioral health

The DBHDS license

Virginia licenses services, not buildings. A provider gets a license from DBHDS for each service it offers, and the service names follow The ASAM Criteria: DBHDS rewrote its regulations to align them with ASAM, and substance use intensive outpatient is ASAM Level 2.1. If you'll also run partial hospitalization (Level 2.5), withdrawal management or residential care, each is its own service with its own sections and its own place in line.

Applications go through the DBHDS CONNECT provider portal. DBHDS's initial applicant orientation says applicants attest that every submitted policy and procedure complies with the licensing regulations; if the documents aren't enough to accept the application, it's rejected with a list of what to fix, and reviewed again when you resubmit. Every policy you submit is a sworn statement, so write them against the regulation, not from a template. For how intensive outpatient differs from partial hospitalization and standard outpatient, see IOP vs. PHP vs. outpatient.

The waitlist and service priorities

This is what makes Virginia different, and it can decide whether you open this year.

• Accepted applications wait. Once DBHDS accepts an application, it goes on a waitlist that the Office of Licensing posts on its website. Priority applicants get a welcome letter with instructions to start background checks and the central registry search.
• Priorities changed in July 2025. A DBHDS memo, Updates to Priority Service Categories and Review Timelines, effective July 30, 2025, sorts services into Priority 1 (essential services with significant unmet need statewide, which DBHDS will prioritize), Priority 2 (adequately available in some areas but still needed) and Non-Priority (already sufficiently available or not aligned with current priorities), with exceptions for local shortages. The memo ends with the list of services by priority. Read where ASAM 2.1 falls before you sign a lease; we couldn't confirm it from what we read.
• A four-phase process. Prioritized services move through a four-phase licensing process, and the final license comes in phase four.
• Medicaid can start early. The orientation says a pending letter can be sent to Medicaid so a new provider can begin providing Medicaid-reimbursable services.

What it means for you. If ASAM 2.1 is Non-Priority, or Priority 2 without a local shortage you can document, plan for a long wait and lease with a way out, or make the case for a local exception with data. Our IOP business plan guide covers how to document local need.

The conditional license

Under 12VAC35-105-50, DBHDS may issue a conditional license to a new provider whose service shows compliance with the administrative and policy regulations but hasn't yet shown compliance with all of them, and a conditional license can't exceed six months. A January 27, 2026 Office of Licensing memo, Limit to One Active Conditional License Per Provider, says a provider may hold only one service on a conditional license at a time, may not add services or locations during the conditional period, and must show progress toward compliance.

Sequence your launch around that: open one service (usually the IOP), run it cleanly through the conditional period with records a reviewer can follow, and only then add outpatient, PHP or a second site. Our chart audit checklist is how we check our own records before a reviewer does.

The ASAM 2.1 rules, line by line

This is what 12VAC35-105-1730 and 1740 require, set beside DMAS's ARTS rules. Build to the stricter of the two.

Requirement	DBHDS regulation	DMAS (ARTS)	What it means for your build
Team	An interdisciplinary team of appropriately credentialed addiction treatment professionals: counselors, psychologists, social workers and addiction-credentialed physicians	An interdisciplinary team of credentialed addiction treatment professionals (CATPs)	Name the team members and their credentials in the staffing plan
Physicians	Specialty training or experience in addiction medicine or addiction psychiatry	May include generalist physicians or physicians with addiction medicine experience (October 2023 criteria)	Hire to the regulation's standard
Mental health literacy	Staff trained in the signs and symptoms of mental disorders and the uses of psychotropic medications	See the ARTS manual	A training log in every staff file
Hours	At least 3 service hours per service day, 9 to 19 hours a week, in a structured environment	Adults: 3 hours a day, average 9 to 19 a week. Children and adolescents: 2 hours a day, average 6 to 19	Three 3-hour days is the adult floor; see the IOP schedule template
Medication	Make MAT available for everyone with opioid or alcohol use disorder	See the ARTS manual	An in-house prescriber or a written referral arrangement; see adding MAT to an IOP
Attendance	Not set separately in what we read	Notify the MCO or Magellan of Virginia when a member's attendance falls below the 2.1 average, so the level of care can be reassessed	Track weekly hours per client and flag drops

Our launch package builds the policy manual as a crosswalk: every requirement in 12VAC35-105 and the ARTS manual matched to a policy, form or record. In Virginia that matters twice, because you attest to the policies when you apply.

Counselors and staffing

• Addiction credentials come from the Virginia Board of Counseling in the Department of Health Professions: the licensed substance abuse treatment practitioner (LSATP), the certified substance abuse counselor (CSAC) and the certified substance abuse counseling assistant (CSAC-A). The CSAC and CSAC-A rules are in 18VAC115-30.
• Supervision first. The Board's supervision registration instructions (revised December 2024) say a CSAC supervisee must have a signed supervisory contract before accumulating supervised experience hours. Register supervision the week someone starts, or their hours won't count.
• Everyone licensed. Section 1730 requires all clinical staff to be qualified by training and experience and licensed, certified or registered by the appropriate health regulatory board. LPCs, LCSWs and psychologists qualify through their own boards.
• Background checks. DBHDS starts background checks and a central registry search during licensing, and every hire and owner should also be checked against the federal OIG exclusion list.

We build personnel files from our staff credential file checklist and add each state's items; in Virginia that includes each supervisee's registered supervisory contract.

Medicaid: ARTS and Cardinal Care

• ARTS. Virginia Medicaid covers substance use treatment through the Addiction and Recovery Treatment Services benefit. The ARTS Provider Manual, Chapter II (updated July 17, 2025) sets provider and staffing requirements by ASAM level.
• Enroll with the license. DMAS's ARTS credentialing page for ASAM levels 2.1 to 4.0 says providers send the DBHDS license for the level of care to the DMAS enrollment vendor and to each MCO to start credentialing and contracting.
• Cardinal Care plans. Since July 1, 2025, Virginia's Medicaid managed care plans are Aetna Better Health of Virginia, Anthem HealthKeepers Plus, Humana Healthy Horizons of Virginia, Sentara Health Plans and UnitedHealthcare of the Mid-Atlantic. Humana replaced Molina. Magellan of Virginia is the behavioral health services administrator for fee-for-service members.
• Medicare pays for IOP and PHP only through hospitals, community mental health centers and a few other provider types, so most freestanding programs plan without it (CMS 2024 outpatient rule).

Our credentialing service handles Medicaid enrollment, plan credentialing and facility contracts in any state, and Medicaid enrollment is $500 per clinician. Before every admission, verify benefits and authorization; the prior authorization guide covers what each plan asks for, and ASAM continued-stay documentation covers the reviews.

We found no Virginia statute specific to patient brokering, but the federal laws apply to every payer. Pay marketers a salary, never per admission; our guide to patient brokering laws explains the federal ones.

The steps, in order

1. Check the priority list in the July 2025 memo for ASAM 2.1 and any other service you want, and look at the current waitlist.
2. Define the program: start with one service, usually ASAM 2.1, adults or adolescents, and a schedule that meets 1740.
3. Form the business with the Virginia State Corporation Commission, get the EIN and the organization NPI, and line up a health-care attorney and CPA.
4. Write the policy manual from 12VAC35-105 and the ARTS manual, plus 42 CFR Part 2 and HIPAA. You'll attest to it.
5. Apply through CONNECT, fix anything the rejection email lists, and get on the waitlist.
6. Find a site local zoning allows, and lease with a way out sized to the wait.
7. Hire the team: a physician with addiction training, LSATPs, CSACs and other licensed staff, with supervision registered.
8. Set up the EHR before the review: Cima's IOP and PHP plan tracks weekly hours per client, group notes, attendance and authorizations.
9. Run the conditional period cleanly, then enroll with DMAS and contract with the Cardinal Care plans.
10. Add services one at a time after the full license, and keep drills and chart reviews on a schedule with the compliance calendar.

Questions

Do you need a license to open an outpatient rehab in Virginia?

Yes. Each service needs a license from the DBHDS Office of Licensing under 12VAC35-105. A substance use IOP is licensed as ASAM Level 2.1 intensive outpatient, under sections 1730 to 1770.

How many hours is an IOP in Virginia?

12VAC35-105-1740 requires at least three service hours per service day and 9 to 19 hours of programming a week. Medicaid's ARTS rules allow two hours a day and an average of 6 to 19 hours a week for children and adolescents.

Why is there a waitlist for a DBHDS license?

DBHDS places accepted applications on a waitlist and, since July 30, 2025, sorts services into Priority 1, Priority 2 and Non-Priority, prioritizing services with significant unmet need. Check where your service falls before you lease.

What is a conditional license in Virginia?

Under 12VAC35-105-50, a license of up to six months for a new provider that meets the administrative and policy regulations but hasn't yet shown compliance with all of them. Since January 2026, a provider can hold only one service on a conditional license at a time and can't add services or locations during it.

Who can counsel in a Virginia IOP?

LSATPs, CSACs and CSAC-As credentialed by the Board of Counseling, and other professionals licensed by their health regulatory boards, as part of the interdisciplinary team section 1730 requires. CSAC supervisees need a signed supervisory contract before their hours count.

Can a Texas company help with a Virginia program?

Yes, if it's honest about how. We run a Texas program, so in Virginia we work from 12VAC35-105, DBHDS's memos and the ARTS manual, check each against the current text, and tell you where DBHDS, DMAS, the plans or your attorney has the final word. We don't guarantee a license, a place on the waitlist, a contract or a date.

Not sure what it will cost all in, wait included? Start with what it costs to start an IOP, or book a free 30-minute call and we'll walk through what Virginia will ask of you.

Cima Consulting isn't a law firm or an accounting firm. Virginia agencies make their own decisions; we don't guarantee approvals, rates or dates. Never pay or accept anything of value for patient referrals: federal law (EKRA and the Anti-Kickback Statute) applies in every state, and ask your attorney about Virginia's own rules.

Sources

• 12VAC35-105: section 50, licenses; section 1730, section 1740, ASAM 2.1 article (law.lis.virginia.gov)
• DBHDS Office of Licensing: initial applicant orientation (June 2023); priority service categories memo (July 2025); one conditional license memo (January 2026); ASAM alignment (2021)
• ARTS: ARTS Provider Manual Chapter II (July 2025); ARTS 2.1 criteria; ARTS credentialing, ASAM 2.1 to 4.0
• Cardinal Care: DMAS press release (July 1, 2025); Cardinal Care managed care
• Board of Counseling: substance abuse supervision registration instructions (December 2024)
• OIG exclusions: oig.hhs.gov; CMS, CY 2024 outpatient rule: cms.gov; EKRA: Cornell LII

Comparing states? See Texas and our guides for Alabama, Arizona, California, Colorado, Delaware, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, South Carolina, Tennessee, Utah, Washington, West Virginia and Wisconsin, or how to start an IOP for what every state has in common.