Texas by city · a free guide from Cima Consulting
How to start an IOP or PHP in Midland–Odessa
The Permian Basin's two cities sit twenty miles apart in two different counties, with two permit offices, one local mental health authority, Medicaid plans from HHSC's rural West service area, and a workforce shaped by the oilfield: shift work, employer health plans and federal drug-testing rules. Here's what that means for opening a substance use intensive outpatient or partial hospitalization program, from operators who run a licensed Texas PHP, IOP and outpatient program.
Updated October 24, 2026. Not legal advice. Cima Consulting isn't a law or accounting firm; confirm building rules with the city and plan line-ups with HHSC before you rely on them.
The short answer: a Midland or Odessa SUD program is licensed by HHSC as a chemical dependency treatment facility, like any Texas program. The building side depends on the city: Midland (Midland County) and Odessa (Ector County) each run their own permits and certificates of occupancy. Both counties are in Texas Medicaid's rural MRSA West service area, where HHSC lists Superior and Wellpoint for STAR and STAR+PLUS and Molina and Superior for CHIP. PermiaCare is the local mental health authority for both counties. Expect commercial and employer plans, and clients under DOT drug-testing rules, to shape the program more than Medicaid does.
Midland–Odessa at a glance
| Question | The Permian Basin's answer |
|---|---|
| State license | HHSC chemical dependency treatment facility license for each site (26 TAC 564) |
| Medicaid service area | MRSA West (the rural West service area), which takes in Midland and Ector counties and much of West Texas |
| STAR plans | Superior HealthPlan, Wellpoint |
| STAR+PLUS plans | Superior HealthPlan, Wellpoint |
| CHIP | Molina, Superior HealthPlan |
| Local mental health authority | PermiaCare: Midland, Ector, Brewster, Culberson, Hudspeth, Jeff Davis, Pecos and Presidio counties |
| Permits and certificate of occupancy | City of Midland building permits; City of Odessa building inspection; the county outside city limits |
| Local watch-outs | Shift schedules; self-funded employer plans; DOT and pipeline testing rules; long distances for clients |
Plans from HHSC's MRSA West STAR comparison chart (October 1, 2026) and HHSC's managed care service areas map; Midland and Ector's place in MRSA West from a CDS service-area table by county. Line-ups change; check them before you apply.
The state license
HHSC licenses Texas substance use programs as chemical dependency treatment facilities under Health and Safety Code chapter 464 and 26 TAC chapter 564. Neither city adds a treatment license. As of October 2026 the fee under 26 TAC 564.408 is $1,200, plus $125 for each additional site.
The per-site rule matters here because the market is two cities. A program that wants an office in both Midland and Odessa has two licensed sites, two sets of building approvals, and two staffing plans that each meet the rule. Most programs open one site where most of their target clients live or work, and add the second when the first is full. The forms are in our Texas CDTF license guide, the proof HHSC wants is in 26 TAC 564 in plain English, and the full sequence is in how to start an IOP or PHP in Texas.
Two cities, two permit offices
- Midland. The City of Midland's building permits page says a certificate of occupancy is issued after final inspection, and only for new construction and changes of occupancy; other permits get a letter of completion on request. So if you move a treatment program into a former office or retail space, plan on a change-of-occupancy permit and a final inspection before you have a certificate in hand. The city also warns that commercial review can take longer than average.
- Odessa. The City of Odessa's code also requires a certificate of occupancy before a building is used or changes use. Ask its building inspection office the same questions, and don't assume an answer from Midland carries over.
- Outside the cities. Addresses in unincorporated Midland or Ector County go through the county. Confirm the jurisdiction from the address before you rely on any city's process.
Ask the office that has jurisdiction, in writing, before you sign:
- What occupancy classification does an outpatient substance use treatment program with group rooms fall under at this address?
- Is moving our program into this space a change of occupancy, and what will the permit and final inspection need?
- What build-out permits and inspections apply, and how long is commercial review taking now?
- What will the fire marshal check before we open?
Then lease with a contingency for the certificate of occupancy and the license. In a market where commercial rents move with the oil price, ask for free rent during the build-out and a clear renewal option. All the site steps are in order in our Texas IOP opening checklist.
Medicaid plans in MRSA West
Midland and Ector aren't in a metro service area. They're in HHSC's rural West service area, so the plans are the rural ones. After the HHSC license, the program enrolls with TMHP and credentials with each plan; TMHP has said Medicaid SUD treatment may only be delivered in a licensed chemical dependency treatment facility (TMHP notice).
| Program | Who it covers | Plans in MRSA West |
|---|---|---|
| STAR | Most children, pregnant women and some families | Superior, Wellpoint |
| STAR+PLUS | Adults with disabilities and adults 65 and older | Superior, Wellpoint |
| CHIP | Children in families above Medicaid income | Molina, Superior |
| STAR Kids | Children and young adults with disabilities | Check HHSC's current map |
- Two applications cover most adults. Superior and Wellpoint are each in STAR and STAR+PLUS here. Superior's facility process is in our Superior HealthPlan guide.
- Wellpoint's rural network is MultiPlan's. In the Medicaid rural service areas, Wellpoint contracts through MultiPlan's Texas True Choice network rather than its own, so a Permian program joins through MultiPlan. Our Wellpoint Texas guide shows the route.
- FirstCare. HHSC's FY2026 STAR rate report listed FirstCare in MRSA West too. FirstCare is part of Baylor Scott & White Health Plan, which said it would leave Texas Medicaid managed care on August 31, 2026 (KWTX). It isn't on HHSC's October 2026 MRSA West STAR chart; confirm before you plan around it.
- Ask about in-lieu-of services for adult PHP and IOP before you build a budget on Medicaid; see our Texas Medicaid IOP and PHP guide.
The order of Medicaid filings is in our Texas Medicaid credentialing guide, and our credentialing service files and follows each application for you.
The oilfield workforce
Energy employers, contractors and trucking shape who comes through the door and who pays. Plan for it from the start.
- Employer plans first. Many oilfield workers are covered by employer health plans, and large employers often self-fund theirs, with a third-party administrator and a rented network on the card. The network on the card, not the employer's name, decides whether you're in network. Verify each client's benefits before admission (our sister site's VOB checklist and behavioral health carve-outs guide show what to ask). Which commercial contracts to pursue first is in insurance contracts for treatment centers.
- Schedule for shifts. Workers on rotating or long shifts can't make a fixed daytime group. Evening tracks, and a written plan for what happens when a client's rotation changes mid-episode, keep attendance and medical necessity documented. Our IOP schedule template shows how programs lay out the hours.
- DOT-tested employees and the SAP. Truck drivers, pipeline workers and other safety-sensitive employees fall under federal testing rules (49 CFR Part 40, with pipeline rules in 49 CFR Part 199). After a violation, a substance abuse professional (SAP) evaluates the employee and recommends education or treatment, and the employee can't return to safety-sensitive work until the SAP's follow-up evaluation finds they complied and a return-to-duty test is negative. Your program may be the treatment the SAP recommends. Send the SAP progress and completion reports only with a consent that meets 42 CFR Part 2.
- Keep SAP referrals clean. Part 40's SAP rules generally bar a SAP from referring an employee to the SAP's own practice or to anyone the SAP has a financial relationship with, with narrow exceptions (Subpart O). If a clinician on your staff also works as a SAP, write a policy that keeps their SAP clients out of your program unless an exception clearly applies. For CDL drivers, the employer and SAP also use FMCSA's Drug and Alcohol Clearinghouse.
The local landscape
Distance is the Permian's defining problem for behavioral health. The Texas Tribune reported in 2023 that Midland and Ector counties together have about 333,000 people, and that patients can travel hours to reach a hospital when a case becomes an emergency (Texas Tribune). Build relationships on fast assessments and honest level-of-care calls, never on payment: the Texas Patient Solicitation Act and federal EKRA ban paying for referrals (patient brokering laws, explained). We never arrange referrals.
- PermiaCare is the local mental health authority for Midland, Ector and six counties to the west and south (TTUHSC's list of area mental health authorities). Agree on crisis hand-offs and where to send clients who need public services you don't offer.
- OSAR. HHSC funds Outreach, Screening, Assessment and Referral programs in every region to connect people with state-funded substance use treatment (HHSC OSAR page). Find the current Permian Basin provider there, and decide whether you'll accept state-funded clients.
- Hospitals and ERs in both cities discharge patients who need a step-down level of care. Their case managers want your levels of care, accepted plans and assessment times.
- Employers, EAPs and safety managers are referral sources unique to this market. Give them a one-page sheet: schedule, levels of care, plans accepted, and how you handle consent and reporting for DOT-tested employees.
- Courts and probation. Specialty courts, including drug courts, operate under Government Code chapter 123; reports go only with Part 2 consent.
The order of work in Midland–Odessa
| Step | Permian detail | Typical time in our roadmap |
|---|---|---|
| 1. Program model and budget | Evening tracks, employer-plan payer mix, which city first. Use the break-even calculator. | 1–2 months |
| 2. Site search | Midland, Odessa or county jurisdiction; the four questions above | about 30 days |
| 3. Lease with a contingency | Out if the certificate of occupancy or license fails; build-out rent and a renewal option | about 3 weeks |
| 4. Build-out | Change-of-occupancy permit; commercial review may run long | about 6 weeks |
| 5. Certificate of occupancy and fire inspection | Issued after final inspection; keep both for HHSC and the accreditor | about 3 weeks |
| 6. HHSC license and inspection | File when the site, policies and staff files are nearly ready | about 2–3 months |
| 7. Facility contracts | Commercial and employer networks; TMHP, Superior and Wellpoint (through MultiPlan) | about 90 days each |
The times are planning figures from our own launch roadmap, not promises. What it costs is in how much it costs to start an IOP.
Opening in the Permian Basin?
Our IOP / PHP Program Launch takes you from plan to first admission for a flat $39,500: the site checklist, the HHSC license, policies (including Part 2 consent for employer and SAP reporting), the clinical program, credentialing with the commercial and Medicaid plans that matter here, and billing.
Or book a free 30-minute call about your plans.
Questions
Which Medicaid plans serve Midland and Odessa?
Midland and Ector counties are in HHSC's rural West service area (MRSA West). HHSC's October 2026 chart lists Superior and Wellpoint for STAR; the map lists Superior and Wellpoint for STAR+PLUS and Molina and Superior for CHIP. Wellpoint's rural network runs through MultiPlan's Texas True Choice.
Do Midland and Odessa have different permit rules?
Yes. They're separate cities in separate counties, each with its own building office. Midland issues a certificate of occupancy after final inspection for new construction and changes of occupancy. Odessa also requires a certificate before a building is used or changes use. Ask the city where your address is.
Who is the local mental health authority for Midland and Ector counties?
PermiaCare, which also serves Brewster, Culberson, Hudspeth, Jeff Davis, Pecos and Presidio counties.
Can an IOP treat employees referred by a DOT substance abuse professional?
Yes, a licensed program can provide the education or treatment a SAP recommends, and report progress to the SAP with the client's Part 2 consent. A SAP generally can't refer to their own practice or to a program they have a financial relationship with, so keep those relationships out of your referral flow.
How long does it take to open an IOP in Midland or Odessa?
Plan on roughly nine to twelve months to a full caseload of insured clients. Commercial review of the build-out and the commercial contracts are usually the long poles.
Other Texas cities: Amarillo, El Paso, Laredo, and every city guide on opening a program in Texas, by city.
Cima Consulting isn't a law or accounting firm. HHSC, the cities and each health plan make their own decisions; we don't guarantee approvals, rates or dates. We aren't affiliated with any health plan named here.
Sources
- HHSC, STAR comparison chart, MRSA West (October 1, 2026): hhs.texas.gov; Managed Care Service Areas map: hhs.texas.gov; FY2026 STAR rates: hhs.texas.gov
- CDS service-area table by county (Midland and Ector in MRSA West): txdisabilities.org; Wellpoint Texas Medicaid service areas: wellpoint.com
- KWTX, Baylor Scott & White Health Plan to exit Texas Medicaid managed care, April 15, 2026: kwtx.com
- City of Midland, building permits: midlandtexas.gov; City of Odessa zoning code, chapter 16 (certificate of occupancy and compliance), as published by Zoneomics: zoneomics.com
- TTUHSC, area mental health authorities (PermiaCare): ttuhsc.edu; Texas Tribune, October 10, 2023: texastribune.org
- 49 CFR Part 40 and Subpart O (SAPs): ecfr.gov; 49 CFR Part 199: ecfr.gov; FMCSA Clearinghouse: fmcsa.dot.gov
- HHSC OSAR: hhs.texas.gov; TMHP, substance use disorder benefit changes: tmhp.com
- Texas Health and Safety Code chapter 464: statutes.capitol.texas.gov; 26 TAC 564.408: justia.com
- Texas Occupations Code chapter 102: statutes.capitol.texas.gov; EKRA: law.cornell.edu; Government Code chapter 123: statutes.capitol.texas.gov; 42 CFR Part 2: ecfr.gov
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