How to start a women's or pregnant and postpartum IOP in Texas

The short answer: a women's or pregnant and postpartum SUD program in Texas needs HHSC's chemical dependency treatment facility (CDTF) license, and a female-only program must also meet 26 TAC 564.910: gender-specific services, women and their dependent children treated as a unit, access to prenatal care, parenting education, documented services to children, and 15 hours a year of child-development training for whoever plans and supervises the program. If you take HHSC treatment funding (the TRF contracts for pregnant women and women with dependent children), the federal block grant rules in 45 CFR 96.124 and 96.131 add child care, case management, transportation, admission preference for pregnant women and interim services within 48 hours. Pregnant women on Texas Medicaid now keep coverage for 12 months after delivery. Methadone or buprenorphine is the recommended treatment for opioid use disorder in pregnancy, and your program's job with CPS is to help the mother build a Plan of Safe Care before the baby arrives.

1. The license and what "women's program" means

Texas has no separate license for a women's program. Any program that treats substance use disorders needs the CDTF license under Health and Safety Code chapter 464 and 26 TAC chapter 564, and the women's rules are extra requirements inside that chapter. How to get the Texas CDTF license covers the application itself, and how to start an IOP in Texas covers the rest of the launch.

Decide early which of these you're building, because the rules attach differently:

Model	What it is	Rules that apply
A women's track in a mixed program	Women-only groups on a women-only schedule, inside a program that also treats men	All of chapter 564. 564.910 is written for female-only specialized programs, but surveyors and payers will expect its substance (trauma, prenatal care, parenting) in the track's charts
A female-only program	The whole program serves women, often with a pregnant and postpartum focus	Chapter 564 plus every part of 564.910
A state-funded women's program	A female-only program with an HHSC treatment contract for pregnant women and women with dependent children	All of the above, plus 45 CFR 96.124 and 96.131 and the contract's own requirements

Programs that also treat depression, anxiety or trauma disorders in the same women need the co-occurring competencies in 564.908; see running a dual diagnosis program in Texas.

2. The 564.910 rules, line by line

These are the women-and-children items we check in a women's program chart, and what a surveyor would look for as proof. HHSC moved the chapter from 25 TAC 448 in 2024 without changing the text, so you may still see the old number (448.910) in older policies.

Requirement	Proof a surveyor looks for
Gender-specific services in female-only specialized programs	Group rosters and a curriculum written for women
Pre-admission service coordination when appropriate	Notes of contact with the referral source, OB or CPS caseworker before day one
Women and their dependent children treated as a unit, with both admitted into treatment when appropriate	Children listed in the assessment and plan, and services to them recorded
Relationship issues addressed, including past or current sexual, physical and emotional abuse	Trauma history in the assessment; plan goals and group topics that address it
Access to primary medical care, including prenatal care and reproductive health education and services	The OB or clinic named in the chart, a release to talk to them, and referral notes
Parenting education and support for pregnant clients, women with dependent children and women whose children are in custody	Parenting sessions attended, by date
Children receive services for their needs and healthy development (such as pediatric care, early childhood intervention and prevention), and those services are documented	Referrals and contacts for each child
Staff competence: a mechanism to make sure direct care staff have the knowledge and skills to serve women and children, and at least 15 clock hours a year of child development or early childhood training for the people who plan and supervise the program	Training certificates in the personnel files of the program director and clinical supervisor
Facilities housing children follow listed sections of the child-care center minimum standards (40 TAC 746, 2003 edition)	Mostly a residential question; see the next section

Everything else in chapter 564 still applies: the assessment within 3 individual service days, the plan within 5, the TB, HIV, hepatitis, STD and tobacco education, group-size limits and discharge follow-up. Our plain-English map of 26 TAC 564 has every deadline, and our chart audit checklist shows how we read a chart for them.

3. Children: child care, family admission and on-site care

A mother can't sit in group without someone watching her children, and child care is where the rules are easiest to misread.

• Outpatient programs don't house children. The 40 TAC 746 standards in 564.910 are written for facilities that house children, which in practice means residential programs where children live with their mothers. An IOP that lets children wait while their mother is in group is a different question.
• Care on site while the mother is in the building. Texas child-care licensing has an exemption, in Human Resources Code 42.041, for care for short periods while parents are on or near the premises, with conditions and limits on hours. Before you open a children's room, describe the arrangement to HHSC Child Care Regulation in writing and keep its answer. Staff the room with people who have background checks and pediatric first aid, and keep a sign-in sheet.
• The alternative many programs use: a partnership with a licensed child-care center nearby, with transport, or child-care help paid through a grant (the CCC program below pays case-by-case child care for eligible women).
• Children in the chart. The children don't become clients, but 564.910 expects their needs and the services they get to be written down: who they are, where they're cared for, their pediatrician, any ECI referral.
• Schedule around them. A daytime IOP that ends before school pickup avoids the sitter an evening program needs. Our IOP schedule templates include a daytime track you can adapt.

4. HHSC funding: TRF, PPI and CCC

Texas funds women's SUD services through several HHSC programs. They're separate contracts with different jobs, and only one of them pays for treatment:

Program	What it pays for	Who it serves	Status when we checked
Treatment for Specialized Females (TRF)	SUD treatment at ASAM levels from outpatient to residential and detox	Adult pregnant women and women with dependent children, including women whose children are in state custody	Awarded with adult (TRA) and youth (TRY) treatment under RFA HHS0015355, a five-year grant that began September 1, 2025; applications closed January 23, 2025
Pregnant and Parenting Intervention (PPI)	Intervention, not treatment: case management, linkage and retention in local services, and evidence-based education	Pregnant women with a past or present SUD, parenting women with a child 6 or younger, and their families	Last solicitation we found was RFA HHS0012453 for fiscal 2024
Comprehensive Continuum of Care for Women (CCC)	Case management: home visits, transportation help, family and peer support, and case-by-case help with housing, utilities, child care and ID documents	Texas women 18+ with an SUD in pre-admission, concurrent or post-treatment services who are pregnant (third trimester) or have dependent children (HHSC CCC page)	Check HHSC for current providers and procurements
SUD services for DFPS clients	SUD services for families involved with Child Protective Services, contracted by HHSC for DFPS	Parents referred by DFPS	Open enrollment HHS0011158, open through August 31, 2027

What this means for a new program: the main treatment grant was just awarded for five years, so a program that opens now usually starts on Medicaid and commercial insurance and builds a record before the next procurement. The DFPS open enrollment is the one door that's open now. A PPI or CCC provider in your area is a natural partner, not a competitor: they case-manage the women your program treats. Partner on fast admissions and good communication, never on anything of value; the Texas Patient Solicitation Act and EKRA apply to grant-funded referral sources too (see patient brokering laws).

5. Federal block grant rules (45 CFR 96)

HHSC's treatment money comes partly from the federal substance use block grant (SUBG, formerly the SAPT block grant). The grant obliges Texas to keep spending at least its fiscal 1994 amount on services for pregnant women and women with dependent children, and programs paid from that money take on duties that a privately funded program doesn't have:

Rule	What the funded program must do
45 CFR 96.124(e)	Provide or arrange primary medical care for the women, including referral for prenatal care and child care while they're in treatment; primary pediatric care for their children, including immunizations; gender-specific treatment that may address relationships, sexual and physical abuse and parenting; therapeutic interventions for the children; and enough case management and transportation for women and children to get to all of it. The family is treated as a unit
45 CFR 96.131(a)	Give pregnant women preference in admission. Programs that treat people who inject drugs admit in this order: pregnant women who inject drugs, other pregnant women, other people who inject drugs, then everyone else
45 CFR 96.131(c)–(d)	A program without room refers the woman to the state, which keeps a capacity system. If no funded program can admit her, interim services, including a referral for prenatal care, must be available within 48 hours of when she asked for treatment
45 CFR 96.131(b)	The state publicizes the preference for pregnant women (outreach, announcements, posters)

Chapter 564 doesn't contain the 48-hour or priority-admission rules, so a program with no HHSC contract isn't bound by them as a licensing matter. They're still good practice: write a same-week admission path for pregnant women into your admissions process whoever pays.

6. Medicaid, CHIP Perinatal and commercial plans

Coverage	What applies
Medicaid for pregnant women	Income-based coverage for pregnant Texans, set in 1 TAC chapter 366; check current limits with HHSC. Members are in STAR managed care plans, so contract with the plans in your area; Texas Children's Health Plan, for example, mostly serves children and pregnant women around Houston. See Texas Medicaid plans by service area
12 months postpartum	Since March 1, 2024, women enrolled in Medicaid or CHIP while pregnant keep 12 months of postpartum coverage, up from 2 (Governor's office and HHSC, after HB 12 in 2023), so a client admitted while pregnant can finish treatment and step down after delivery on the same coverage
CHIP Perinatal	Doesn't get the 12 months: coverage ends at the end of the month the pregnancy ends, plus two postpartum visits (Wellpoint HB 12 notice). Aetna Better Health's notice also excludes CHIP Perinate from PHP and IOP. Verify these clients carefully
The CDTF rule	Medicaid SUD treatment must be delivered in a licensed CDTF, since January 1, 2019 (TMHP)
Adult PHP and IOP	Paid by Medicaid plans as in-lieu-of services that each plan may choose to offer, with prior authorization; see Texas Medicaid for IOP and PHP programs
TRICARE	Military spouses and service members. TRICARE pays IOP and PHP only to accredited programs certified as TRICARE-authorized; see TRICARE IOP and PHP certification
Commercial plans	Most working women and spouses. Verify the SUD benefit, authorization rules and whether a behavioral health company manages it before admission; our VOB checklist lists what to ask

Our credentialing service files the facility contracts with each Medicaid and commercial plan, and the Texas Medicaid guide covers TMHP enrollment first.

7. Medication for opioid use disorder in pregnancy

A pregnant woman with opioid use disorder should be offered medication, and a women's program that discourages it is out of step with every major guideline:

• The guidance. ACOG's Committee Opinion 711, written with ASAM, recommends opioid agonist treatment over medically supervised withdrawal in pregnancy because withdrawal carries high relapse rates, and recommends universal screening with a validated tool. SAMHSA's Clinical Guidance for Treating Pregnant and Parenting Women With Opioid Use Disorder and Their Infants (2018) covers prenatal, infant and postpartum care, and the CDC summarizes methadone and buprenorphine as first-line, with medication continued after delivery.
• Who prescribes. Since the 2023 MAT Act, any practitioner with a DEA registration that covers Schedule III can prescribe buprenorphine for opioid use disorder without the old X-waiver (SAMHSA). Methadone for OUD still comes only from an opioid treatment program; see starting an OTP in Texas.
• Your program's role. Coordinate with the prescriber and the OB, with a Part 2 release for each; record every dose your staff give or supervise (564.1004); keep naloxone on site and send it home with clients (naloxone policy). Adding MAT to an IOP covers the medical director, the prescriber model and billing.
• Postpartum. Plan the weeks after delivery before the delivery: who prescribes, how dose changes are handled, how she gets to group with a newborn, and screening for postpartum depression.

8. CPS, substance-exposed newborns and Plans of Safe Care

This is the question pregnant clients ask first, and the one you must answer honestly without promising an outcome.

• The federal frame. CAPTA requires states to have policies for health care providers to notify child protective services about infants affected by substance use or withdrawal, and to develop a Plan of Safe Care that addresses the needs of both the infant and the family.
• Texas. DFPS develops a Plan of Safe Care for infants affected by or exposed to substance use, case by case, with input from the parents, caregivers and the professionals involved (Child Welfare Information Gateway summary of Texas policy). Texas rules treat a mother's prenatal use of a substance that wasn't lawfully prescribed, or wasn't taken as prescribed, as possible neglectful supervision or physical abuse of the infant in defined circumstances (same source, parental substance use). Medication prescribed for her and taken as prescribed isn't what those definitions describe.
• Your staff's duty. Texas professionals must report suspected abuse or neglect of a child within 48 hours of first having reasonable cause to believe it, and can't delegate the report (Family Code 261.101). 42 CFR 2.12 lets a Part 2 program make reports of suspected child abuse and neglect that state law requires, but it doesn't open the rest of the record for later proceedings without a court order. Write a CPS reporting policy that says who decides, who reports and what is shared.
• What helps the mother most. Start the Plan of Safe Care in treatment, weeks before delivery, with her consent: a letter from her prescriber confirming the medication and dose, her attendance and drug screen history, her OB and pediatrician, her supports at home, and releases for the hospital social worker. Give the hospital and DFPS a documented, prescribed treatment history to build the plan from, rather than a positive screen with no context.

Our drug testing policy guide covers who sees results and under what consent, which matters more here than anywhere.

9. Staffing

• Counselors. The same as any CDTF: QCCs (LCDCs, or other licensees with 1,000 hours of documented SUD experience), graduates and supervised counselor interns. See IOP staffing requirements in Texas.
• The 15 hours. The program director and clinical supervisor each need 15 clock hours a year of child development or early childhood education training (564.910). Put it on the training calendar.
• Women clinicians for women's groups. Not a rule we found in chapter 564, but gender-specific services are; we'd staff women's groups with women clinicians.
• A case manager. Prenatal appointments, WIC, Medicaid renewals, housing, child care and transport compete with treatment for a mother's time. 96.124 requires case management in funded programs; every women's program needs it.
• A medical director and OB relationships. A medical director for the program and a working relationship with at least one OB practice that treats patients on MOUD. See the medical director for an IOP or PHP.
• Peer specialists with lived experience of recovery as mothers carry weight in groups and outreach.

10. Designing the program week

• Curriculum. Trauma-informed groups, relationships and intimate partner violence, parenting, prenatal and postpartum health, and the required TB, HIV, hepatitis, STD and tobacco education. Our IOP group curriculum has the core topics to build on.
• Safety planning. Screen for intimate partner violence privately, with a safety plan and local shelter contacts. Never send program mail or texts a partner might read without asking how she wants to be contacted.
• Screening. A validated perinatal depression screen at intake and after delivery, suicide risk screening with a same-day path, and the TB, HIV, hepatitis C and STD testing access chapter 564 requires.
• Family. Family sessions and a parenting group; see building an IOP family program.
• Step-down and discharge. Plan the move from IOP to outpatient around the delivery date, not in spite of it, and line up postpartum supports before discharge (discharge planning for IOP and PHP).

Or book a free 30-minute call.

11. Women's program opening checklist

• CDTF license for the site and levels of care; operational plan describing the women's program, ages, levels and schedule.
• Policy on 564.910: gender-specific services, pre-admission coordination, children as part of the unit, prenatal care access, parenting education, services to children documented.
• Admission policy with a same-week path for pregnant women (and the 96.131 order if you take HHSC money).
• Child-care plan: an exemption answer from HHSC Child Care Regulation for any on-site room, or a licensed partner and transport.
• MOUD policy: no client turned away for prescribed medication, prescriber and OB coordination, dose records, naloxone.
• CPS reporting policy (48 hours, no delegation), Part 2 release forms for the OB, pediatrician, hospital and DFPS, and a Plan of Safe Care template.
• Intimate partner violence screening and safety plan; perinatal depression and suicide screening.
• 15 hours of child-development training for the director and clinical supervisor on the calendar.
• Contracts with the Medicaid STAR plans in your area and the commercial plans; a verification step for CHIP Perinatal clients.
• A partner list: OB practices, the local PPI and CCC providers, WIC, ECI, shelters, the OSAR for your region.

Questions

Can a woman bring her children to an outpatient treatment program in Texas?

Chapter 564 expects women and their dependent children to be treated as a unit, and many outpatient programs offer care for children while the mother is in group. Texas child-care licensing has an exemption for short-term care while parents are on the premises, with conditions and hour limits, so confirm your arrangement with HHSC Child Care Regulation before you open a children's room. Residential programs that house children follow child-care center standards.

Does Texas Medicaid cover substance use treatment for pregnant women?

Yes. Pregnant women who qualify for Medicaid are covered for SUD treatment delivered by a licensed chemical dependency treatment facility, through their STAR plan, and since March 1, 2024 they keep coverage for 12 months after the pregnancy ends. CHIP Perinatal coverage is narrower and ends soon after delivery. Each plan sets its own authorization rules for IOP and PHP.

Will CPS take my baby if I'm on Suboxone or methadone in Texas?

No program can promise an outcome, but medication prescribed for opioid use disorder and taken as prescribed is the recommended treatment in pregnancy, and Texas rules on prenatal exposure are aimed at substances that weren't lawfully prescribed or weren't taken as prescribed. DFPS builds a Plan of Safe Care for infants exposed to substances; a documented treatment history, a prescriber's letter and an engaged mother are what that plan is built on.

Is buprenorphine or methadone safe during pregnancy?

ACOG and SAMHSA guidance recommends medication (methadone or buprenorphine) over withdrawal for pregnant women with opioid use disorder, because withdrawal carries a high risk of relapse, and recommends continuing it after delivery. The choice between them is a decision for the woman and her prescriber.

Do pregnant women get priority for treatment in Texas?

In programs funded by the federal block grant through HHSC, yes: 45 CFR 96.131 gives pregnant women preference in admission and requires interim services, including a prenatal care referral, within 48 hours if no funded program can admit her. The rule isn't in the Texas licensing rules, so privately funded programs aren't bound by it, but a fast admission path for pregnant women is good practice.

What is Texas's Pregnant and Parenting Intervention (PPI) program?

An HHSC-funded intervention program, not treatment, for pregnant women with a past or present substance use disorder and parenting women with a child 6 or younger, and their families. It provides case management, linkage to local services and education. You can reach a PPI program directly, through your region's OSAR or through the local mental or behavioral health authority.

What does 26 TAC 564.910 require?

For female-only programs: gender-specific services, pre-admission coordination when appropriate, women and dependent children treated as a unit, services addressing abuse and relationships, access to prenatal and reproductive care, parenting education, services to children documented, staff competence in serving women and children, and 15 clock hours of annual child-development training for program planners and supervisors.

Sources

• 26 TAC 564.910, Treatment Services for Women and Children (Justia, current through March 2025); Texas Register transfer notice from 25 TAC 448; Texas Health and Safety Code ch. 464
• 45 CFR 96.124 and 96.131 (Cornell LII); 42 CFR 2.12
• HHSC: RFA HHS0015355 (TRA, TRF, TRY); RFA HHS0012453 (PPI); Comprehensive Continuum of Care for Women; open enrollment HHS0011158 (SUD services for DFPS)
• Office of the Governor, Medicaid and CHIP postpartum coverage extension to 12 months; Wellpoint, HB 12 postpartum coverage notice; TMHP, SUD benefit change, January 1, 2019
• ACOG, Committee Opinion 711, Opioid Use and Opioid Use Disorder in Pregnancy (2017); SAMHSA, Clinical Guidance for Treating Pregnant and Parenting Women With Opioid Use Disorder and Their Infants (2018) and MAT Act page; CDC, Treatment of opioid use disorder before, during and after pregnancy
• Child Welfare Information Gateway, Plans of Safe Care: Texas and Parental substance use as child abuse: Texas; Texas Family Code ch. 261; Texas Human Resources Code ch. 42

All checked October 24, 2026. Cima Consulting isn't a law firm and doesn't give legal or medical advice. This page paraphrases the rules; the official text controls, and HHSC procurements change, so check the current solicitation before you plan on grant revenue.