Michigan Drug and Alcohol Outpatient Treatment Licensing

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.

LARA contact: BCHS Non-Long Term Care State Licensing Section, 1-833-757-7308, LARA-BCHS-NLTCSLS@michigan.gov

Michigan stopped licensing outpatient substance use disorder treatment as its own program category on June 3, 2026. That is the date revised Substance Use Disorder Administrative Rules took effect. Those rules, issued by the Department of Licensing and Regulatory Affairs (LARA), Bureau of Community and Health Systems (BCHS), give a license exactly three program service categories to authorize in R 325.1303(6)(d), and outpatient is missing from the set. If you came here expecting a walkthrough of an outpatient SUD license application, there isn’t one to file anymore. What follows is what still applies to an outpatient operator, what changed, and the one outpatient service that still needs a LARA license.

What the June 2026 Rules Actually License

LARA still licenses substance use disorder services programs under Part 62 of the Public Health Code. The statute hasn’t changed: MCL 333.6233(1) says a person not otherwise licensed to provide psychological, medical, or social services “shall not establish, conduct, or maintain a substance use disorder services program unless it is licensed under this part.” What changed is how the rules define a program. R 325.1301(1)(jj) now describes a program as an entity offering treatment and rehabilitation services “that include methadone programs, residential programs, and residential withdrawal management programs.” R 325.1303(6)(d) lists the same three as the only program service categories a license can authorize. Before the revision, that list opened with “Outpatient counseling program.”

Those three make up the complete list. Neither outpatient counseling nor intensive outpatient appears on it, and in the current rule text we reviewed, the word “outpatient” doesn’t show up anywhere.

What a Michigan Outpatient SUD Provider Needs Now, and What It Doesn’t

An outpatient clinic that offers counseling, intensive outpatient groups, or office-based buprenorphine, with no methadone and no residential beds, does not fit any category LARA now licenses. In our reading, that means no LARA SUD program license, no $500 annual license fee, and no LARA prelicensure or renewal surveys for that clinic. That is our interpretation of the rule text, not a statement LARA has published in those words. MCL 333.6233 still bars running an unlicensed “substance use disorder services program,” and the clinic’s position rests on the rules now defining that term narrowly, so get LARA’s answer in writing (1-833-757-7308 or LARA-BCHS-NLTCSLS@michigan.gov) before you build a business plan on it.

The moment a program adds methadone dosing or a residential component, it is back inside Part 62 and needs a license for that category. Our reading is that outpatient services run alongside a licensed residential program don’t make the outpatient side licensable, though the residential side still carries the full rule set. Clinicians are a separate matter: R 325.1303(3) lets an individual licensed under Article 15 provide services within the scope of that license without a program license, provided they aren’t working under a group or organization offering SUD services and aren’t providing methadone.

Methadone Is the Outpatient Service That Still Needs a License

A methadone program is still a licensed LARA category, and mobile units are licensed only as attachments to a “state-licensed methadone program location” (R 325.1301(1)(x)). R 325.1303(5) requires a prelicensure survey for methadone programs and says LARA will decide on a complete application within 3 months. For filing, LARA’s Non-Long Term Care page points licenses, changes, and renewals to the Michigan State Licensing System (MI-SLS). Under MCL 333.6237 the license fee is $500 a year “Until October 1, 2027,” and the same LARA page says “License renewals must be paid no later than July 31st.”

The federal side runs in parallel. Under 42 CFR 8.11, an opioid treatment program needs a current certification from the Secretary of HHS, accreditation by an approved accreditation body, and DEA registration “before administering or dispensing MOUD,” and it must comply with state law, which in Michigan means the LARA methadone license. If the OTP will take public funding through a PIHP, MDHHS adds its own condition: Treatment Policy #05 in the department’s Substance Use Disorder Services Policy Manual requires the program to be accredited by CARF, the Council on Accreditation (COA) or The Joint Commission (TJC). Those three are also the accreditors we see across Michigan’s other SUD programs. The methadone rule also sets its own staffing floor: R 325.1383(2) requires the program to “employ a licensed counselor, LMSW, licensed psychologist, or LMFT.”

If Your Program Held an Outpatient License Before June 3, 2026

The revised rules don’t lay out a process for programs that held an outpatient counseling license under the old version. We couldn’t find a grandfather clause, a refund policy, or a conversion step in the rule text. What LARA’s Non-Long Term Care page does cover is plain non-renewal: “All licenses not renewed by September 1st will have the license closed,” with a notice sent, and “A provider’s non-renewal of a license by September 1st is not considered as a refusal to renew by the department.” The rules also say, in R 325.1305(6), that a license can’t be renewed if the location hasn’t offered the covered service in the 12 months before the renewal period. So an outpatient-only license that wasn’t renewed this summer should simply close rather than be treated as a department refusal. For a program that held outpatient alongside residential or methadone, our expectation is that renewal covers only the categories that still exist. Ask LARA to confirm in writing what your license now authorizes, and keep that letter, because payers and auditors who remember the old system will ask about it.

What Governs Outpatient Practice Instead

With no facility license, the rules that matter for an outpatient clinic sit with the people doing the work and the payers funding it.

Counselor certification still runs through the Michigan Certification Board for Addiction Professionals (MCBAP), which “is a member of the International Certification and Reciprocity Consortium (IC&RC).” A CADC needs 300 education hours whatever the degree; what scales is the counseling experience (6,000 hours with a high school diploma, down to 2,000 with a master’s) and the supervision (300 hours down to 100). The CAADC requires a master’s degree, 186 education hours, 2,000 hours counseling people with SUD, and 100 supervision hours. Staff working toward a credential list it with “-DP” after it, and MCBAP is clear that “A Development Plan is not a credential.”

Professional licensure is where outpatient operators should slow down. Part 181 of the Public Health Code says “a person shall not engage in the practice of counseling unless licensed or otherwise authorized,” and the clinical counseling definition in MCL 333.18101 covers treatment plans for “An addiction disorder.” Section 18115(2)(c) exempts “An individual who is employed by or who volunteers to work in a substance use disorder services program licensed by the department under part 62.” An outpatient-only clinic no longer holds that license. Our reading is that its MCBAP-certified counselors who are not also an LPC, LLPC, social worker, psychologist, or MFT may not be able to rely on that exemption anymore. Section 18115(1) separately protects licensed social workers, psychologists, MFTs and physicians who counsel within their own licenses. We have not seen LARA or the Michigan Board of Counseling address this gap, so treat it as an open question and get guidance before you staff a clinic entirely with certified-only counselors.

Payers fill in the rest. If you plan to bill Medicaid through a regional PIHP or community mental health program, expect its contract and credentialing standards to do much of what the LARA license used to do. Macomb County Community Mental Health’s administrative requirements for new providers, posted in August 2026, say contracted SUD agencies “must apply for and obtain MDHHS approval for each ASAM level of care” they intend to offer, and “All providers must enroll in the CHAMPS system.” Each region sets its own requirements, so read your PIHP’s provider manual directly.

No Certificate of Need for Outpatient SUD Care

Michigan’s Certificate of Need law covers the “health facility” types listed in MCL 333.22205(1): hospitals, psychiatric hospitals and units, nursing homes, freestanding surgical outpatient facilities, and HMOs. An outpatient SUD clinic isn’t on that list, and the June 2026 change doesn’t alter that.

Medication for Opioid Use Disorder in Outpatient Care

An outpatient program treating opioid use disorder still needs a clear medication pathway, and LARA’s rules for licensed programs require policies that “facilitate access to medication-assisted treatment if desired by the recipient.” Buprenorphine no longer needs a separate federal waiver; DEA’s January 12, 2023 letter to registrants says “all prescriptions for buprenorphine only require a standard DEA registration number.” Methadone is the exception, since only a licensed and federally certified OTP can dispense it, so a clinic without one needs a working referral relationship with an OTP. One example is Premier Services of Michigan, operating as CMS Dearborn Heights at 25639 Ford Road, which CARF lists with a three-year accreditation for its opioid treatment program. A reviewer will give more weight to a named OTP partner than to a line saying you refer out.

A Stand-Alone Ketamine Clinic in Michigan

Michigan has no ketamine clinic statute. The no-facility-license conclusion and the ownership structure below are our reading of LARA’s licensing list, the professional corporation statute and the Attorney General opinion we cite, so have Michigan health care counsel confirm them for your deal.

Michigan has no rule aimed at ketamine clinics, which keeps the facility licensing question short. LARA’s Non-Long Term Care section licenses acute care hospitals, freestanding birth centers, hospice agencies and residences, freestanding surgical outpatient facilities, psychiatric hospitals or units, and SUD services programs. A physician practice giving ketamine for depression isn’t on that list. It isn’t an SUD program either, and since June 3, 2026 outpatient care isn’t a licensable SUD category in any case. What the clinic does need is attached to the drug and to the people prescribing it.

Ownership: A Professional Corporation, Not a Lay Company

Michigan is a corporate practice state. The Attorney General’s opinion No. 5676 (April 8, 1980) concluded that a for-profit corporation to provide osteopathic services, 25 percent owned by a lay person, “may not be formed solely under the Business Corporation Act,” holding that it had to be organized under the Professional Service Corporations Act, and relied on an earlier opinion holding that furnishing medical services was not a lawful corporate purpose. LARA later declined to issue a declaratory ruling on whether a for-profit medical company must be a professional corporation, saying the statute already answers it, and quoted MCL 450.1281(1), “A corporation must incorporate as a professional corporation,” and MCL 450.1283(2), “Each shareholder of a professional corporation must be a licensed person.” The exceptions LARA described let physicians form a professional corporation with osteopathic physicians, podiatrists or physician assistants. Nurse practitioners aren’t among them, so in our reading an NP can’t co-own the medical PC. An LLC doesn’t get around this. The LLC Act says a company “formed to provide services in a learned profession” shall comply with its article 9 (MCL 450.4201), and article 9 requires each member and manager to be a licensed person in a service the company provides (MCL 450.4904(1)).

Investors therefore sit in a management services organization that contracts with the physician-owned PC for space, staff, billing and marketing. Keep clinical decisions, prescribing protocols and the controlled substance license with the PC, and pay the MSO a fee that doesn’t track the volume of ketamine sessions it brings in. That fee structure is our recommendation, not a Michigan rule.

Licenses, MAPS and Who Can Prescribe

The PC needs a DEA registration and a Michigan controlled substance license for the clinic’s address, since MCL 333.7303 requires “a separate license” at each principal place of practice. Each prescriber must register with MAPS before prescribing or dispensing any schedule 2 to 5 drug, and must review a MAPS report before a prescription for more than a 3-day supply (MCL 333.7303a). APRNs prescribe ketamine only as a delegated act of a physician (MCL 333.17211a; 2016 PA 499), so put the delegation in writing and name the drug. A Spravato line needs certification in the Spravato REMS and at least two hours of observation after each dose.

Co-locating with an outpatient SUD practice or a licensed methadone program is common. The PC should still hold its own charts, inventory and controlled substance license for the address, and addiction treatment records should reach it only on the patient’s written consent. For residential programs that start a series and refer residents here after discharge, the referral cautions are in the ketamine section of Michigan Drug and Alcohol Inpatient Treatment Licensing.

Staffing an Outpatient Program

Payroll is usually where a new operator’s budget first collides with reality. A small outpatient program typically needs a clinical director and two to three counselors. With the state median for substance abuse, behavioral disorder, and mental health counselors at $61,960 a year (BLS OEWS, May 2024), slightly ahead of the roughly $59,350 national number, that core team usually adds up to $190,000 to $260,000 a year in clinical payroll before benefits. Few Michigan clinics actually write that full check, since MCBAP’s two-tier system gives you somewhere to land in between. A common approach staffs the clinic with CADC-level counselors, some still completing their certification under a Development Plan, working under a CAADC clinical director, an arrangement that saves on salaries and lets counselors grow into the higher credential. Since June 2026, check that model against the Part 181 counseling question above, because pairing certified counselors with at least one licensed clinician may now matter more than it did. We build the detailed staffing matrix and budget after the service mix is locked in.

Where Michigan Outpatient Operators Get Tripped Up Now

The most common mistake right now is following pre-June 2026 advice, including our own older guidance, and preparing an outpatient license application for a category the current rules don’t list. The second is assuming that losing the license means losing every obligation. Payer contracts, counselor credentialing, and Part 181 still apply, and a program that adds methadone or residential beds is back in front of LARA.

Frequently Asked Questions

Not sure where your Michigan outpatient program stands after the June 2026 rule change? Reach out here.

Sources

• Mich. Admin. Code R 325.1301 to R 325.1399 (eff. June 3, 2026): LARA SUD Administrative Rules PDF (checked October 8, 2026)
• Mich. Admin. Code R 325.1303, 2023 version (LII mirror): prior service categories (checked October 8, 2026)
• LARA BCHS, MI-SLS filing and renewal deadlines: Non-Long Term Care State Licensing (checked October 9, 2026)
• Public Health Code Part 62, MCL 333.6230 to 333.6251: Substance Use Disorder Services (checked October 8, 2026)
• Public Health Code Part 181, MCL 333.18101, 333.18105 and 333.18115: Counseling (checked October 8, 2026)
• Public Health Code Part 222, MCL 333.22205: Certificate of Need (checked October 8, 2026)
• 42 CFR 8.11: Opioid treatment program certification (checked October 8, 2026)
• DEA Diversion Control, January 12, 2023: Dear Registrant letter on the DATA-Waiver (checked October 8, 2026)
• MCBAP: MCBAP Certifications and home page (IC&RC membership) (checked October 8, 2026)
• Macomb County Community Mental Health: New Provider Training, Administrative Requirements (checked October 8, 2026)
• CARF provider listing: Premier Services of Michigan LLC, CMS Dearborn Heights (checked October 8, 2026)
• MDHHS, Substance Use Disorder Services Policy Manual, Treatment Policy #05: OTP accreditation by CARF, COA or TJC (PDF) (checked October 8, 2026)
• eCFR, 21 CFR 1308.13(c)(7): ketamine as a Schedule III depressant (checked October 9, 2026)
• U.S. FDA: Spravato prescribing information and Medication Guide, REMS and two-hour monitoring (checked October 9, 2026)
• Michigan Attorney General, OAG No. 5676 (April 8, 1980): Corporations providing osteopathic services (checked October 9, 2026)
• LARA, declaratory ruling on learned professions and MCL 450.1281 to 450.1289: Learned profession order (PDF) (checked October 9, 2026)
• Michigan Limited Liability Company Act, MCL 450.4201 and article 9 (MCL 450.4901 to 450.4910), Michigan Legislature: LLC purposes, learned professions and Professional limited liability companies (checked October 9, 2026)
• Public Health Code, MCL 333.7303: Controlled substance license, separate license for each place of practice (checked October 9, 2026)
• Public Health Code, MCL 333.7303a: MAPS registration and report review (checked October 9, 2026)
• LARA, MAPS: Laws and regulations (checked October 9, 2026)
• 2016 PA 499, MCL 333.17211a: APRN prescribing, schedule 2 to 5 as a delegated act (checked October 9, 2026)