Author: A. Ant, CADC-II, Licensing & Accreditation Expert
Disclaimer: This content is provided for general informational purposes only and should not be construed as legal, regulatory, or licensing advice. Requirements change frequently. Consult qualified professionals for guidance specific to your situation.
Apply now: KDADS New Program Application (SUD treatment) | Questions: Wendy Jacobs, Behavioral Health Services Licensing Manager, Wendy.Jacobs@ks.gov or 785-596-3161
Kansas charges $100 to license an outpatient addiction program, and the legislature wrote that ceiling into the statute. K.S.A. 65-4013 lets the secretary set an application fee “not to exceed $100,” and the Kansas Department for Aging and Disability Services (KDADS) charges exactly that, “$100.00 per program location.” The catch is the last two words. A group with an IOP in Wichita and a counseling office in Hutchinson files two applications and pays twice, and each site gets its own license tied to its own premises. Money is rarely what slows a Kansas outpatient opening. The paperwork behind each location is.
Residential modalities, the accreditation track in detail and the ketamine rules for a residence are in Kansas Drug and Alcohol Inpatient Treatment Licensing. For psychiatric outpatient clinics, read Kansas Mental Health Outpatient Licensing, and the full state picture is on Kansas Behavioral Health Licensing.
Outpatient Modalities on the Kansas Application
Modality names and standard numbers come from the 2006 Standards and the New Program Application, both posted by KDADS.
KDADS still reviews SUD programs against the “Standards for Licensure/Certification of Alcohol and/or Other Drug Abuse Treatment Programs,” a 2006 rulebook that still carries the name of the agency that issued it, the Department of Social and Rehabilitation Services (SRS). The outpatient side of it has four service types an operator would normally pick from, and the application asks you to check each one you will run.
| Modality on the application | Standard | Notes |
|---|---|---|
| Early Intervention/Interim Services | R03-702 | Optional |
| Outpatient Counseling | R03-703 | Optional |
| Outpatient Intensive | R03-704 | Optional |
| Alcohol and Drug Assessment and Referral Program | R03-712 | The application marks it “Required by all programs” |
That last row surprises people. Even a clinic that only wants to run an evening IOP has to build and document an assessment and referral function, because the application lists it as required for every program. The packet also expects your assessment tools, naming the KCPC or another instrument along with screens such as the SASSI or MAST. Opioid maintenance (R03-711) sits on the same list but is a separate track we don’t cover here.
When a Clinician’s Practice Is Not a Treatment Facility
Private practitioners often ask whether they need this license at all. The answer sits in K.S.A. 59-29b46, which K.S.A. 65-4024a borrows for the meaning of “treatment facility.” The current text, in force since January 1, 2026, does not reach “a professional licensed by the behavioral sciences regulatory board to diagnose and treat mental disorders at the independent level or a physician” whose ordinary caseload includes some substance use while the clinician stays “not primarily engaged” in treating it. It also excludes licensed medical care facilities and anything licensed under the 39-2001 mental health act.
Read that closely and the exclusion is narrower than it first sounds. A psychiatrist or independent-level therapist whose caseload is mostly anxiety and depression, with some patients who drink too much, fits it. An addiction-focused practice does not, because treating substance use is what it is primarily engaged in. Our reading is that a solo LCAC running an addiction practice is a treatment facility and needs the KDADS license. KDADS hasn’t published guidance on this point, so put the question to the licensing manager if your practice is close to the line.
Fees, Terms and Site Changes at a Glance
| Event | What Kansas requires | Source |
|---|---|---|
| New program | Application plus $100 per location, filed at least 90 days before opening. KDADS approves or denies within 90 calendar days once the file is complete | K.S.A. 65-4013, R03-802 |
| Renewal | License renewed for 1, 2 or 3 years depending on compliance. $100 renewal fee due within 2 weeks of the licensure visit notice | K.S.A. 65-4014, R03-803 |
| Inspection | Required at least once per license term | K.S.A. 65-4018 |
| Adding a modality or site | Application, director’s name, policy declaration, org chart and evidence of sufficient qualified staff. Decision within 90 calendar days | R03-808 |
| Moving the office | Notice at least 30 days before the move | R03-808 |
| Waiver of a standard | Written request, decided within 30 days | R03-807 |
The term is the number to watch. K.S.A. 65-4014 lets the secretary renew “at the end of one, two or three years,” and R03-803 ties the length to compliance. On our reading, a clean first cycle is how a program earns the longer term. The license also stays with the named premises and persons and can’t be transferred without written approval, which matters if you plan to sell or reorganize the practice.
Accredited Outpatient Programs
An outpatient program that already holds a KDADS license and gets accredited by CARF, The Joint Commission, COA or another KDADS-approved body “shall be granted a license based on such accreditation,” per K.S.A. 65-4014(b)(2). KDADS runs this through what its forms call certification. The Certified Renewal Application is for a program “in good standing with a National Behavioral Accreditation Body or has a Mental Health License,” and R03-806 says KDADS keeps visiting to examine client records. The inpatient guide walks through the statutory wording. For outpatient, our practical take is simple: accreditation won’t skip your first KDADS review, but it changes what renewal looks like.
Treatment Plan Reviews and the 180-Day Memo
KDADS posts a document on its licensing page labeled “12.26.24 180 Day Treatment Plan Memo,” and operators sometimes read it as permission to update outpatient treatment plans every six months. It isn’t. The memo, dated December 26, 2024, is a staff recommendation to the Commissioner of Behavioral Health Services about “allowing for 180-day treatment planning,” and the posted copy still carries reviewer comments objecting to it, including this one: “If we allow this for SUD services within CCBHC’s, we would need to allow for all outpatient SUD providers.” Nothing in it is an adopted rule. A second posted document on CCBHC criteria says treatment plans “must be completed every 90 days” under state criteria, but it applies only to certified community behavioral health clinics. Write your review interval to the 2006 Standards and don’t cite the memo in your manual.
Buprenorphine and Methadone Coordination
Nothing we found in Kansas statute or the 2006 Standards obliges an outpatient SUD program to provide MOUD. Adding buprenorphine is mostly a prescriber question now. DEA told registrants on January 12, 2023 that “all prescriptions for buprenorphine only require a standard DEA registration number.” Under R03-609(B)(2), any medication the program itself gives must be “administered only by a medical professional or nurse or self-administered by the client.” Methadone belongs to opioid maintenance programs licensed under R03-711, which need a physician medical director, SAMHSA and DEA compliance and “An approved accrediting body.” A clinic without one should name the program its clients dose at and spell out in policy how the two share information.
Opening a Ketamine Clinic in Kansas
Kansas has no ketamine clinic law. The facility-license conclusion is our interpretation of K.S.A. 59-29b46 and 39-2006. The ownership, prescribing and drug rules are quoted from the court decision, statutes and rules linked below.
No Kansas license that we could find covers a doctor’s office giving ketamine infusions for depression. The SUD license reaches “treatment facilities,” and 59-29b46 leaves out physicians who aren’t primarily engaged in treating substance problems, so a depression-focused infusion practice falls outside 65-4012 on our reading. The 39-2001 mental health act is less clear. Under K.S.A. 39-2006 no one may “be a provider of services” without a KDADS license, and its definition of provider turns on rules we couldn’t find for private practices. We treat that question as open. A clinic whose main business is treating addiction would be back under the SUD license.
Who Can Own It
Kansas has appellate case law on corporate practice. In Early Detection Center, Inc. v. Wilson, 248 Kan. 869 (1991), two physicians converted their professional corporation into a general corporation and sold 40 percent of the stock to two men who weren’t licensed to practice medicine. The Kansas Supreme Court held that “A general corporation is prohibited from providing medical services or acting through licensed practitioners.” The professional corporation statute keeps the door shut from the other side. K.S.A. 17-2712 says a professional corporation “may issue the shares of its capital stock only to a qualified person,” meaning someone licensed in the same profession, and any other issuance “shall be null and void.” A 1996 Attorney General opinion describes a later case, St. Francis Regional Medical Center v. Weiss, as allowing a licensed hospital to employ physicians, but we haven’t read that decision and a ketamine clinic isn’t a hospital anyway.
So the workable build is a Kansas physician-owned professional corporation that holds the medical license, the DEA registration and every clinical decision, paired with a management services company that investors can own. The management company supplies the lease, equipment, front desk and billing, and charges a fair-market fee set in advance rather than a cut of infusion revenue. Have counsel draft both agreements with Early Detection Center in mind.
Since the October 2022 rule amendments, Kansas treats APRNs as independent decision-makers. K.A.R. 60-11-101, as amended effective October 14, 2022, says each APRN “shall be authorized to make independent decisions,” and K.A.R. 60-11-104a lets an APRN “prescribe, procure, or administer any drug that is a controlled substance” under the controlled substances act. The Attorney General Opinion 2026-7 (March 23, 2026), advisory rather than binding and written at the request of the Board of Pharmacy’s counsel, concludes that APRNs and PAs “must hold the appropriate Kansas license from their respective boards to have prescriptive authority in the state.” Our reading is that an NP licensed only in another state should get Kansas licensure before prescribing here. Because the professional corporation act lists registered professional nurses among its professions, a nurse-owned corporation is a structure counsel can evaluate, though that is our reading and not something we have seen tested for a ketamine practice.
Registrations, K-TRACS and Spravato
Under 21 CFR 1308.13(c)(7) ketamine is a Schedule III substance, and DEA wants a registration for “each principal place of business or professional practice” (21 CFR 1301.12), so a second clinic address means a second registration. The Kansas Board of Pharmacy registration in K.S.A. 65-4116 doesn’t add a step for physicians, whose healing arts license “shall constitute compliance” at their practice location. A “mid-level practitioner” also appears on the statute’s no-registration list, but the section doesn’t define the term, so an APRN-led clinic should get the Board of Pharmacy’s answer in writing. K-TRACS collects dispensing data for schedules II through IV and excludes a practitioner “who administers such a substance,” so in-office infusions aren’t reported on our reading. Take-home prescriptions are a different matter.
The Kansas State Board of Nursing hasn’t spoken to ketamine. The board’s 2014 position statement on IV moderate sedation covers RNs acting on a physician’s order and names no drug at all, which leaves a psychiatric infusion protocol to your medical director’s judgment. A Spravato service needs REMS certification, and the FDA label requires that “patients are monitored by a healthcare provider for at least 2 hours after administration of SPRAVATO.” Some of your first patients may arrive partway through a series that began in residential treatment. The referral and kickback rules for that handoff, and what a residence can do before discharge, are in the ketamine section of Kansas Drug and Alcohol Inpatient Treatment Licensing.
Who Staffs a Kansas Outpatient Clinic
The Behavioral Sciences Regulatory Board licenses addiction counselors at three levels. Under K.S.A. 65-6610 the LAC rests on a bachelor’s earned in an addiction counseling program, or a board-approved bachelor’s plus substance use coursework, and some existing BSRB licensees qualify directly. The LMAC is the master’s-level version with similar routes. The LCAC adds two years of postgraduate supervised work: 3,000 hours in total, 1,500 spent with clients on substance abuse assessment and treatment, and no fewer than 100 hours of face-to-face supervision. The LCAC matters for intake in particular, because under the board’s packet an LAC cannot make the substance use disorder diagnosis, and every Kansas program runs the assessment and referral function. Board fees are modest: $50 to apply, $150 for the exam, and an original license of $100 for an LAC or $150 for an LMAC or LCAC.
For substance abuse, behavioral disorder, and mental health counselors, Kansas posted a $59,470 median wage in federal survey data (OEWS, May 2025), within $120 of the national median of $59,350. A quarter of Kansas counselors earn less than $44,370 and a quarter earn more than $73,630. An outpatient team of an LCAC clinical director and four counselors, all at the median, costs about $297,350 a year in salary (5 x $59,470, our estimate) before benefits and payroll taxes. That figure assumes a fully licensed clinician in every chair, and a new Kansas clinic rarely has to open that way. Hire LMACs who are working toward their 3,000 LCAC hours, have your LCAC director provide the supervision they need, and pay them accordingly, and counseling payroll usually lands 40 to 60 percent under a roster staffed entirely with LCACs. One detail from the 2026 session shows how tight the pipeline is: House Bill 2506, which would have created an addiction counselor apprentice license, died after a February hearing where the BSRB testified against it. If you add medication services, an RN can oversee LPNs who handle routine administration. We set the final headcount from your modalities and weekly group schedule.
How to Submit Your KDADS Outpatient Application
File the New Program Application for each location, built from the checklist in the New Program Application Packet. Expect to assemble a manual specific to your site and cross-referenced to each R03 standard in the packet’s review table, the employee list with each person’s BSRB credential, an org chart that shows the board, certificates of liability and malpractice insurance, the fire marshal’s fire and safety inspection, your admission packet with client rights and confidentiality forms, assessment tools and release of information forms. Include the $100 fee for the location.
The SUD forms were last revised in January 2017 and still name Stephanie Simpson at 612 S. Kansas Avenue as the contact. KDADS’s newer forms for other license types list Wendy Jacobs, Behavioral Health Services Licensing Manager, at Wendy.Jacobs@ks.gov and 785-596-3161, and the Survey, Certification and Credentialing Commission now gives 503 S Kansas Ave., Topeka, KS 66603-3404 as its address. Email first and ask where the SUD packet should go. KDADS has 90 days from a complete application, and we plan on roughly 3 to 6 months from filing to license for an outpatient program.
Outpatient Delays We See in Kansas
Generic manuals are the first problem, and the packet already warns that general policies won’t be accepted. The second common gap is the assessment and referral program, which applicants treat as a checkbox instead of a written service with its own tools and staff. The third is a multi-site plan filed as one application when Kansas wants one per location.
Frequently Asked Questions
How much does a Kansas outpatient SUD license cost?
K.S.A. 65-4013 caps the application fee at 100 dollars, and KDADS charges 100 dollars per program location. Renewal is another 100 dollars per location, due within two weeks of the licensure visit notice. Each site files its own application.
Does a private practice therapist in Kansas need a KDADS SUD license?
Not always. K.S.A. 59-29b46 excludes physicians and independent-level BSRB licensees who see some substance use in their regular caseload without being primarily engaged in treating it. In our reading an addiction-focused practice is primarily engaged and needs the license, so confirm with KDADS if you are close to the line.
Can a lay investor own a ketamine clinic in Kansas?
Not the medical practice itself. Kansas case law (Early Detection Center, Inc. v. Wilson, 1991) keeps general corporations from providing medical services, and K.S.A. 17-2712 restricts professional corporation stock to licensees in the same profession. Investors usually own a management services company that contracts with a physician-owned practice.
Planning more than one Kansas outpatient site? We can help sequence the applications.
Sources
- KDADS: Behavioral Health Licensing (checked October 16, 2026)
- KDADS: Survey, Certification, and Credentialing Commission (checked October 16, 2026)
- KDADS, R03-101 to R03-810: Standards for Licensure/Certification of Alcohol and/or Other Drug Abuse Treatment Programs, 2006 (PDF) (checked October 16, 2026)
- KDADS: New Program Application (checked October 16, 2026)
- KDADS: New Program Application Packet (checked October 16, 2026)
- KDADS: Certified Renewal Application (checked October 16, 2026)
- KDADS: 12.26.24 180 Day Treatment Plan Memo and CCBHC Areas of State Discretion, 8.1.2024 (checked October 16, 2026)
- KDADS: Private Psychiatric Hospital new application, licensing manager contact and renewal application, updated 2025 (checked October 16, 2026)
- K.S.A. 65-4013: Application and fee (checked October 16, 2026)
- K.S.A. 65-4014: License term and accreditation (checked October 16, 2026)
- K.S.A. 65-4018 (Justia mirror): Inspections (checked October 16, 2026)
- K.S.A. 65-4024a: Definitions (checked October 16, 2026)
- K.S.A. 59-29b46: Definition of treatment facility (checked October 16, 2026)
- K.S.A. 39-2002 and 39-2006: Definitions and License required (checked October 16, 2026)
- BSRB: Addiction Counselors and LCAC reciprocity packet (checked October 16, 2026)
- K.S.A. 65-6610 (Justia mirror): Addiction counselor license qualifications (checked October 16, 2026)
- Kansas Legislature, 2026 HB 2506: Addiction counselor apprentice license (died) (checked October 16, 2026)
- U.S. Bureau of Labor Statistics, OEWS May 2025, SOC 21-1018: Kansas and national estimates (checked October 16, 2026)
- DEA Diversion Control Division: Dear Registrant letter, January 12, 2023 (PDF) (checked October 16, 2026)
- Early Detection Center, Inc. v. Wilson, 248 Kan. 869 (1991), OpenJurist mirror: Opinion (checked October 16, 2026)
- K.S.A. 17-2707 and 17-2712: Professional corporation definitions and Share ownership (checked October 16, 2026)
- Kansas Attorney General Opinion 96-34: Corporate practice and hospital employment of physicians (checked October 16, 2026)
- Kansas Attorney General Opinion 2026-7: Prescriptive authority of PAs and APRNs (PDF) (checked October 16, 2026)
- K.A.R. 60-11-101 and 60-11-104a: APRN independent decisions and APRN prescription orders (checked October 16, 2026)
- Kansas State Board of Nursing: Administration of IV Conscious Sedation by the Registered Professional Nurse (PDF) (checked October 16, 2026)
- K.S.A. 65-4116: Controlled substance registration (checked October 16, 2026)
- K-TRACS: Reporting to K-TRACS (checked October 16, 2026)
- 21 CFR 1308.13(c)(7), via Cornell LII: Schedule III, ketamine (checked October 16, 2026)
- 21 CFR 1301.12, via Cornell LII: Separate registrations for separate locations (checked October 16, 2026)
- U.S. FDA: Spravato prescribing information, REMS and monitoring (PDF) (checked October 16, 2026)

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