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: email ProviderCert@odmhsas.org for an ODMHSAS Certification Application Packet (process overview) | Questions: ODMHSAS Provider Certification, 405-248-9029
An Oklahoma LADC or licensed professional counselor can see addiction clients in a private office without any program certification at all. That freedom has a sharp edge, and it is written into the same statute. Under 43A O.S. 3-415(E), the exemption for practitioners “shall apply only to individual professional persons in their private practice” “and not to any treatment facility operated by the person.” Once an office starts to function as a treatment program, it has to be certified by the Oklahoma Department of Mental Health and Substance Abuse Services (ODMHSAS), and operating an uncertified program is a misdemeanor under 3-415(A).
Residential, halfway house and withdrawal management programs are in Oklahoma Drug and Alcohol Inpatient Treatment Licensing. Clinics treating mental illness rather than addiction sit under other rules, explained in Oklahoma Mental Health Outpatient Licensing, and Oklahoma Behavioral Health Licensing lays out how the state’s agencies divide the work.
Who the Statute Leaves Out, and Where That Stops
The exemption list below is taken from the text of 43A O.S. 3-415 on OSCN, which shows no amendment since 2021. Where the line falls for a growing group practice is our own reading.
Section 3-415(E)(1) names the professionals whose private practice is exempt: licensed physicians, psychologists, social workers, registered nurses, licensed professional counselors, licensed marriage and family therapists, licensed behavioral practitioners, clergy, and licensed or certified alcohol and drug counselors. The same subsection exempts properly licensed hospitals, programs run by state agencies, Alcoholics Anonymous, the Salvation Army and faith-based nonresidential recovery programs. Federally defined health centers are exempt too, except for “services listed in Levels 2.1 through 4 of the Levels of Care,” so in our reading an FQHC that adds an intensive outpatient track comes back under certification.
The hard cases are offices that grow. One LPC with a caseload is plainly a private practice. A suite with a clinical director, scheduled groups, intake staff and a written treatment schedule looks a lot more like a “treatment facility operated by the person,” and in our view that is the point to stop relying on the exemption. The statute gives no headcount. If you’re somewhere in between, put the question to Provider Certification in writing before you advertise a program name.
One Outpatient Level, and No IOP Chapter
Chapter 18 of ODMHSAS’s rules (OAC 450:18, effective September 1, 2025) lists outpatient services as “ASAM Level 1” in 450:18-13-1 and defines them in 450:18-13-21 as “organized non-residential services with scheduled treatment sessions.” The table of contents still shows “PART 5. INTENSIVE OUTPATIENT SERVICES [REVOKED],” and the list of levels contains no 2.1. We read that as meaning Oklahoma no longer certifies IOP as a separate service under Chapter 18. It doesn’t tell you how ODMHSAS treats a nine-hour-a-week schedule today, so describe the intensity you plan in your program description and ask Provider Certification how it will be certified before you print a brochure. Section 450:18-13-21 assigns each outpatient service to specific credentials:
| Outpatient service (450:18-13-21) | Who may provide it |
|---|---|
| Individual, family and group therapy | Licensed Behavioral Health Professional (LBHP) or Licensure Candidate |
| Crisis intervention | LBHP or Licensure Candidate |
| Rehabilitation services | LBHP, Licensure Candidate, Certified Alcohol and Drug Counselor (CADC) or Case Manager II |
| Case management | LBHP, Licensure Candidate, CADC, Case Manager II or Case Manager I |
| Peer services | Peer Recovery Support Specialists certified under OAC 450:53 (450:18-13-222) |
A CADC can run rehabilitation groups and case management but not therapy, which shapes the hiring plan more than anything else in the chapter.
Medication for Opioid Use Disorder in an Outpatient Clinic
Oklahoma treats outpatient and residential programs differently here. Section 450:18-5-5.1 makes residential, halfway house and withdrawal management providers give consumers access to MAT medications, directly or by formal agreement. A full-text search of Chapter 18 turned up no matching duty for outpatient programs, which means the choice to offer or arrange MOUD is yours. We’d keep at least a written referral arrangement, and in our experience a named partner works better than a generic list.
Office-based buprenorphine is the easy addition. The DEA’s January 12, 2023 letter says that, going forward, “all prescriptions for buprenorphine only require a standard DEA registration number,” and the prescriber also needs an Oklahoma State Bureau of Narcotics and Dangerous Drugs Control registration under 63 O.S. 2-302. Methadone stays with opioid treatment programs, which ODMHSAS certifies under a chapter of their own (Chapter 70). An outpatient clinic coordinates with one when a client needs it.
Stand-Alone Ketamine Clinics Under Oklahoma Law
No Oklahoma statute or agency rule addresses ketamine clinics, and we found no ODMHSAS or OSDH facility category that fits one. The facility and ownership points here are our interpretation of the statutes linked. The prescribing limit comes straight from the Board of Nursing’s formulary.
A practice giving ketamine for depression doesn’t appear to need a state facility license. We found no OSDH or ODMHSAS category for an office infusion clinic, and ketamine for depression isn’t alcohol or drug treatment under 3-415, as we read it. Add addiction treatment to the menu and that changes, because the clinic is then providing services 3-415 says only certified programs may offer.
Who Owns It
Oklahoma has no corporate practice of medicine statute, rule or appellate ruling that we could locate, so a flat answer either way would be overstating it. What does exist is the Professional Entity Act. Under 18 O.S. 809, no one may hold an interest in a domestic professional entity unless licensed or otherwise permitted to render the same or related professional services, and 18 O.S. 803 lists physicians among the professions it covers. Investors who aren’t physicians commonly sit in a management services organization that leases the space, employs non-clinical staff and bills the physician-owned practice a fixed fee. Clinical decisions and the controlled substance registrations belong to the practice.
Why a Nurse Practitioner Can’t Run the Prescribing
Oklahoma’s APRNs gained independent prescriptive authority under 59 O.S. 567.4c (HB 2298, effective November 1, 2025), and many operators assume that opens the door to an NP-led ketamine practice. It doesn’t. The Board of Nursing’s Exclusionary Formulary lists “Ketamine (Ketalar),” and it binds APRNs with independent authority as well as supervised ones. A CRNA’s controlled substance authority under the Nursing Practice Act (59 O.S. 567.3a) runs to anesthesia given in collaboration with a physician, dentist or podiatrist and is limited to the anesthesia and perioperative or periobstetrical periods. Whether a depression infusion counts is not something we’d assume. Plan on a physician writing every ketamine order. As for RNs giving the drug, we found no Board of Nursing position on low-dose ketamine, and its moderate sedation guideline doesn’t mention it.
DEA, OBNDD, the PMP and Spravato
Each clinic address gets its own DEA registration, because 21 CFR 1301.12 requires one “for each principal place of business or professional practice.” Ketamine is Schedule III in Oklahoma’s own list (63 O.S. 2-208), so the OBNDD registration under 2-302 applies, and OAC 475:25-1-3 keeps records readily retrievable for two years. Prescription monitoring reporting under 63 O.S. 2-309C is tied to drugs “dispensed pursuant to a valid prescription,” which in our reading leaves in-office infusions unreported. A clinic offering Spravato must be certified in the REMS, and the Spravato Medication Guide requires monitoring “for at least 2 hours” after each dose.
Many patients will come straight from a residential stay. The referral rules for that handoff, including Oklahoma’s patient brokering statute and the federal kickback law, are in the ketamine section of Oklahoma Drug and Alcohol Inpatient Treatment Licensing.
Counselor Pay and a Leaner Outpatient Roster
Oklahoma counselors earn a statewide median of $59,350 a year (BLS OEWS, May 2025, substance abuse, behavioral disorder, and mental health counselors), exactly the national median in the same release. A quarter of the state’s counselors earn $41,930 or less, and a quarter earn $79,620 or more. A small clinic with a clinical director, two therapists and a CADC handling rehabilitation groups and case management is four salaries, about $237,400 a year at the median (4 x $59,350, our estimate) before benefits and front-desk staff. Most new outpatient programs never carry that full amount, because Oklahoma lets supervised candidates deliver much of the work. The table above lets a Licensure Candidate, someone receiving board-approved supervision, provide therapy, and the Board of Licensed Alcohol and Drug Counselors requires 12 months and 2,000 hours of employment for the LADC and 24 months and 4,000 hours for the CADC. Built around one licensed clinical director and a bench of candidates still logging those hours at sub-licensed wages, a clinic’s counseling payroll typically runs 40 to 60 percent lighter than it would with every seat held by a licensed clinician. If the clinic runs a medication service, one RN overseeing a couple of LPNs is the usual arrangement. We size the actual team around your group schedule and caseload.
How to Submit Your ODMHSAS Outpatient Application
The application isn’t posted online. You request a Certification Application Packet from Provider Certification at ProviderCert@odmhsas.org, and the agency sends it electronically, according to its overview of the certification process. Calls go to 405-248-9029. (The 405-248-9325 number shown on the main Provider Certification page is, per the overview, the fax for critical incidents only.) Mail goes to ODMHSAS, 2000 N. Classen Blvd., Suite 2-600, Oklahoma City, OK 73106.
Chapter 1 sets the treatment-program fee at $1,000 per certification period (OAC 450:1-9-6), right at the ceiling 43A O.S. 3-324 places on a certification fee. Expect to supply an inspection report from your city fire department or the State Fire Marshal, with any cited items cleared, and a zoning compliance letter on the local authority’s letterhead, then work through a self-survey, up to three rounds of policy review and an initial health and safety visit. The ODMHSAS Board considers a Permit for Temporary Operations at a board meeting, and that permit lets you start seeing clients. It runs six months, ending with a review of at least five active records and discharge records, and certification follows for one or two years. Anything the agency asked for that hasn’t arrived 60 days after it received your application leads to denial under 450:1-9-7.
Expansion is simpler once you’re certified. Under 450:1-9-6.1, a new location doesn’t need its own PTO if your certification is in good standing and isn’t itself a PTO, unless the new site offers services you aren’t already certified for. Section 450:1-9-6.2 lets you add optional services within the scope of your existing chapter on request.
Accreditation and the Three-Year Term
Accreditation won’t replace ODMHSAS certification for an addiction program, but it does lengthen it. Under 450:1-9-5.7, a program that has provided services under ODMHSAS certification can earn “Certification with Special Distinction” for up to three years if it holds COA, CARF or Joint Commission accreditation for the certified services. ODMHSAS also “may accept” that accreditation “as compliance with certain specific ODMHSAS standards” under 450:1-9-7.3(b), on submission of the survey reports. For a clinic planning to grow, three years between renewals is a real saving of staff time.
Where Outpatient Applications Stall
Two problems account for most of what we see. One is a program description written around an IOP level that Chapter 18 no longer lists, which forces a rewrite. The other is a staffing plan that has CADCs delivering therapy, which 450:18-13-21 reserves for LBHPs and Licensure Candidates. Both are easy to fix before submission and slow to fix after the policy review clock is running.
Frequently Asked Questions
Does a solo counselor in Oklahoma need ODMHSAS certification to treat addiction?
Not for an individual private practice. 43A O.S. 3-415(E) exempts licensed professionals such as LADCs, CADCs, LPCs and social workers in their private practice, but the exemption does not cover any treatment facility the person operates. A practice that grows into a program with staff and scheduled groups should ask Provider Certification whether it needs certification.
Does Oklahoma certify intensive outpatient programs separately?
Not under its current rules as we read them. Chapter 18 lists outpatient services as ASAM Level 1, and the former Part 5 on intensive outpatient services is marked revoked. Ask ODMHSAS Provider Certification how a more intensive schedule will be certified before you finalize your program description.
How much does ODMHSAS outpatient certification cost?
The application fee for treatment programs is 1,000 dollars per certification period under OAC 450:1-9-6, payable to ODMHSAS. That matches the statutory cap in 43A O.S. 3-324. Fire inspection, zoning documentation and staffing are separate costs.
Not sure whether your growing practice has crossed into program territory? Ask us about it.
Sources
- OSCN, 43A O.S. 3-415: Certification of alcohol and drug treatment facilities, exemptions (checked October 16, 2026)
- OSCN, 43A O.S. 3-324: Certification fees (checked October 16, 2026)
- ODMHSAS: Provider Certification (checked October 16, 2026)
- ODMHSAS: New programs, overview of the ODMHSAS certification process (checked October 16, 2026)
- ODMHSAS, OAC 450 Chapter 1 (eff. September 1, 2025), sections 450:1-1-1.1, 1-9-5.7, 1-9-6, 1-9-6.1, 1-9-6.2, 1-9-7, 1-9-7.3: Administration (PDF) (checked October 16, 2026)
- ODMHSAS, OAC 450 Chapter 18 (eff. September 1, 2025), sections 450:18-5-5.1, 13-1, 13-21, 13-222 and Part 5: Substance Related and Addictive Disorder Treatment Services (PDF) (checked October 16, 2026)
- ODMHSAS: Administrative rules currently in effect, including Chapter 70 (checked October 16, 2026)
- DEA Diversion Control Division: Dear Registrant letter, January 12, 2023 (PDF) (checked October 16, 2026)
- 63 O.S. 2-302 (Justia mirror): OBNDD registration (checked October 16, 2026)
- OSCN, 18 O.S. 803 and 809: Professional Entity Act definitions and ownership limits (checked October 16, 2026)
- OSCN, 59 O.S. 567.4c: APRN independent prescriptive authority (checked October 16, 2026)
- Oklahoma Board of Nursing: Independent prescriptive authority notice, HB 2298 (checked October 16, 2026)
- Oklahoma Board of Nursing: Exclusionary Formulary for APRNs with prescriptive authority (PDF) (checked October 16, 2026)
- Oklahoma Board of Nursing: Oklahoma Nursing Practice Act, 59 O.S. 567.3a (PDF) (checked October 16, 2026)
- Oklahoma Board of Nursing: Guideline P-06, moderate sedation (PDF) (checked October 16, 2026)
- 63 O.S. 2-208 (Justia mirror): Schedule III, ketamine (checked October 16, 2026)
- OSCN, 63 O.S. 2-309C: Prescription monitoring program reporting (checked October 16, 2026)
- OAC 475:25-1-3 (Cornell mirror): OBNDD practitioner records (checked October 16, 2026)
- 21 CFR 1301.12 (Cornell mirror): Separate registrations for separate locations (checked October 16, 2026)
- U.S. FDA: Spravato prescribing information and Medication Guide (PDF) (checked October 16, 2026)
- Oklahoma Board of Licensed Alcohol and Drug Counselors: Basic requirements for LADC and CADC (PDF) (checked October 16, 2026)
- U.S. Bureau of Labor Statistics, OEWS May 2025, SOC 21-1018: Oklahoma and national estimates (checked October 16, 2026)

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