Texas by city · a free guide from Cima Consulting
How to start an IOP or PHP in San Antonio
What's local about opening a substance use intensive outpatient or partial hospitalization program in San Antonio and the eight-county Bexar Medicaid service area: the city's permits, a Medicaid line-up that changed in 2024, a large military population on TRICARE, and serving clients in Spanish. 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 zoning with the city and plan line-ups with HHSC before you rely on them.
The short answer: a San Antonio SUD program needs HHSC's chemical dependency treatment facility license, like any Texas program, plus the city's zoning approval, building permits and certificate of occupancy for the site. San Antonio is in Texas Medicaid's Bexar service area (Atascosa, Bandera, Bexar, Comal, Guadalupe, Kendall, Medina and Wilson counties). HHSC's map lists Aetna, Community First, Superior and Wellpoint for STAR, and Community First, Molina and UnitedHealthcare for STAR+PLUS. For military families, TRICARE pays an IOP or PHP only once it is accredited.
San Antonio at a glance
| Question | San Antonio's answer |
|---|---|
| State license | HHSC chemical dependency treatment facility license, per site (26 TAC 564) |
| Medicaid service area | Bexar: Atascosa, Bandera, Bexar, Comal, Guadalupe, Kendall, Medina and Wilson counties |
| STAR plans | Aetna Better Health, Community First Health Plans, Superior HealthPlan, Wellpoint |
| STAR+PLUS plans | Community First Health Plans (since September 1, 2024), Molina, UnitedHealthcare Community Plan |
| CHIP / STAR Kids | CHIP: Aetna, Community First, Superior, Wellpoint. STAR Kids: Community First, Superior |
| Local mental health authority | The Center for Health Care Services (Bexar County); surrounding counties have their own |
| Zoning and certificate of occupancy | City of San Antonio Development Services Department (start at sanantonio.gov); New Braunfels, Schertz, Seguin, Boerne and others have their own |
| Local watch-outs | The 2024 STAR+PLUS changes; TRICARE's accreditation rule; bilingual staff and materials |
Plan line-ups from HHSC's managed care service areas map; counties from HHSC's STAR comparison charts. Check both before you apply; they change with HHSC's contracts.
The state license
There's no San Antonio treatment license. HHSC licenses SUD programs statewide as chemical dependency treatment facilities under Health and Safety Code chapter 464 and 26 TAC 564. As of October 2026 the fee under 26 TAC 564.408 is $1,200 plus $125 for each additional site, so a second location in New Braunfels or Schertz means another site on the license and another building to approve. The application and inspection are in our CDTF license guide; the full sequence is how to start an IOP or PHP in Texas.
Zoning, permits and the certificate of occupancy
San Antonio regulates land use through its Unified Development Code, and the City of San Antonio Development Services Department handles zoning questions, building permits and certificates of occupancy (start at sanantonio.gov). Cities in the surrounding counties run their own. Ask the right office, in writing, before you sign:
- How is an outpatient substance use treatment program with group rooms classified, and is it allowed in this zoning district by right?
- If it isn't, what approval is needed, and does it go to a hearing?
- Does the current certificate of occupancy cover our use and expected occupancy?
- What permits and inspections will the build-out need, and how long does review take?
- What will the fire marshal check before we open?
Then sign a lease with a contingency for zoning, the certificate of occupancy and the license, and free rent for the build-out. The Texas IOP opening checklist has every step.
Medicaid plans in the Bexar service area
After the HHSC license, enroll with TMHP and apply to 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 the Bexar service area |
|---|---|---|
| STAR | Most children, pregnant women and some families | Aetna Better Health, Community First, Superior, Wellpoint |
| STAR+PLUS | Adults with disabilities and adults 65 and older | Community First, Molina, UnitedHealthcare |
| STAR Kids | Children and young adults with disabilities | Community First, Superior |
| CHIP | Children in families above Medicaid income | Aetna Better Health, Community First, Superior, Wellpoint |
What changed in 2024. STAR+PLUS in Bexar was re-awarded. Community First Health Plans says HHSC selected it for STAR+PLUS in the Bexar service area effective September 1, 2024, and calls itself the area's only locally owned, nonprofit plan (Community First announcement). Superior says it no longer provides STAR+PLUS coverage in the Bexar service area (Superior notice), though it still serves STAR there: its 2026 STAR directory for Bexar covers the same eight counties. HHSC's STAR+PLUS plan code table shows the same dates. If you're reading an older payer list, it's probably wrong.
- Adult program: Community First is the one plan in both STAR and STAR+PLUS here, so it's a natural first application, followed by Molina or UnitedHealthcare for STAR+PLUS (UnitedHealthcare's behavioral health runs through Optum; see carve-outs) and Aetna, Superior or Wellpoint for STAR.
- Adolescent program: Community First and Superior appear in STAR, STAR Kids and CHIP.
The steps for TMHP and each plan are in our Texas Medicaid credentialing guide; for commercial plans, see insurance contracts for treatment centers and our credentialing service.
TRICARE and Military City USA
San Antonio calls itself Military City USA: Joint Base San Antonio and Brooke Army Medical Center bring active-duty families, retirees and veterans. For an IOP or PHP, that makes TRICARE worth planning for, with conditions. Since January 1, 2025, Texas has been in TRICARE's West region, so programs join through TriWest Healthcare Alliance. And TRICARE pays an IOP or PHP only under a participation agreement that requires accreditation (TRICARE Policy Manual, IOP participation agreement); programs usually use the Joint Commission, CARF or COA, but confirm the accepted list with TriWest. A brand-new program can't get there on day one, so plan the accreditation timeline with the TRICARE contract in mind. Our TRICARE credentialing guide and accreditation for new programs explain the order, and the Program Launch + Accreditation package carries a program all the way through. Veterans using VA benefits go through the VA's community care network, a separate process.
Serving clients in Spanish
Many San Antonio clients and families prefer Spanish. Texas rules already ask for it in places: under 26 TAC 564.506, the client bill of rights, HHSC's complaint information and the grievance procedure are posted in English and a second language (see 26 TAC 564 in plain English). Beyond the postings, plan for bilingual counselors or an interpreter policy, Spanish intake packets and consents, and at least one Spanish-language group if demand supports it. Accreditors look for language access in the intake and treatment-planning records.
The local landscape
Referral relationships are earned with fast admissions and honest updates, never with payment: the Texas Patient Solicitation Act and EKRA ban paying for referrals (our patient brokering guide). We don't arrange referrals.
- Hospital systems: University Health, Bexar County's public system; the Methodist, Baptist and CHRISTUS Santa Rosa systems; and San Antonio State Hospital. Case managers want your levels of care, plans and assessment times.
- The local mental health authority: The Center for Health Care Services is Bexar County's authority for public mental health and substance use services, including crisis care. Put the crisis hand-off in writing.
- OSAR: HHSC's Outreach, Screening, Assessment and Referral programs connect people to state-funded treatment; find the one for your counties on HHSC's OSAR page.
- Courts and probation: Bexar County runs specialty courts, including drug courts, under Government Code chapter 123. Reports need the client's consent under 42 CFR Part 2.
Opening in San Antonio?
Our IOP / PHP Program Launch takes you from plan to first admission for a flat $24,500, with facility credentialing for the Bexar-area plans. Want TRICARE? The Program Launch + Accreditation package is $32,500.
Or book a free 30-minute call about your site and payer plan.
Questions
Which Medicaid plans serve San Antonio?
HHSC's map lists Aetna Better Health, Community First, Superior and Wellpoint for STAR; Community First, Molina and UnitedHealthcare for STAR+PLUS; Community First and Superior for STAR Kids; and Aetna, Community First, Superior and Wellpoint for CHIP in the Bexar service area.
Does Superior still cover STAR+PLUS in San Antonio?
No. Superior says it no longer provides STAR+PLUS coverage in the Bexar service area; Community First took on STAR+PLUS there on September 1, 2024. Superior still serves STAR members in Bexar.
Can a new San Antonio IOP take TRICARE?
TRICARE pays IOPs and PHPs only under a participation agreement that requires accreditation (programs usually use the Joint Commission, CARF or COA), and in Texas you join through TriWest. So a new program usually contracts with TRICARE after accreditation. Plan the accreditation survey early if military families are part of your market.
Are New Braunfels and Seguin in the Bexar Medicaid service area?
Yes. The Bexar service area includes Comal (New Braunfels) and Guadalupe (Seguin, part of Schertz) counties, along with Atascosa, Bandera, Bexar, Kendall, Medina and Wilson. Each city has its own zoning and permits.
How long does opening a San Antonio IOP take?
Plan on nine to twelve months to a full caseload of insured clients, longer if TRICARE or other plans that need accreditation are central to your plan.
Other metros: Austin, El Paso, and all six on opening a program in Texas, by city.
Cima Consulting isn't a law or accounting firm. HHSC, the city, TRICARE and each health plan make their own decisions; we don't guarantee approvals, rates or dates.
Sources
- HHSC, Managed Care Service Areas map: hhs.texas.gov; STAR comparison charts (Bexar counties): hhs.texas.gov; STAR+PLUS plan codes (revision 25-5): fhb.hhs.texas.gov
- Community First Health Plans, STAR+PLUS award: communityfirsthealthplans.com; Superior, STAR+PLUS coverage update: superiorhealthplan.com; Superior 2026 STAR Bexar directory: superiorhealthplan.com
- Molina STAR+PLUS service area (Bexar counties): molinahealthcare.com
- Texas Health and Safety Code chapter 464: statutes.capitol.texas.gov; 26 TAC 564.408: justia.com
- TMHP, substance use disorder benefit changes: tmhp.com; TRICARE: tricare.mil; TRICARE Policy Manual, IOP participation agreement: manuals.health.mil; HHSC OSAR: hhs.texas.gov
- 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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