1. Behavioral Health Workforce Research Center. Scopes of Practice for Behavioral Health Professionals. Accessed November 2018 at

  2. See

  3. Authorization for independent practice is not uniformly documented; in some states, we made an inference from available documentation in the absence of direct evidence for this capability.

  4. CMS, Medicare Coverage of Substance Abuse Services,, accessed December 31, 2018. SUPPORT for Patients and Communities Act, 2018,, accessed September 9, 2019.

  5. See, accessed December 31, 2018.

  6. Optum Provider Express,, accessed October 11, 2018.

  7. National Association of State Alcohol and Drug Abuse Directors (NASADAD). (2013). State Regulations on Substance Use Disorder Programs and Counselors: An Overview. Retrieved from

  8. See

  9. See

  10. Padwa, H., & Oeser, B. (2013). White Paper on California Substance Use Disorder Treatment Workforce Development. Los Angeles, CA: UCLA Integrated Substance Abuse Programs.

  11. For a description of this waiver opportunity, see the July 2015 letter from the Centers for Medicare & Medicaid Services to state Medicaid directors, available at

  12. ASAM levels 3.7 and 4.0 are currently not covered under the ODS. However, the state working to include these levels under the waiver.

  13. U.S. Census Bureau, Population Division. (2018). Annual Estimates of the Resident Population: April 1, 2010 to July 1, 2017. Available at

  14. Wilhelm, P. (2016). DMC-ODS at the Starting Blocks: Insights from Phase I. A study for the California Senate Office of Research on the expansion of substance use treatment under California's Medi-Cal 2020 waiver. Berkeley, CA: University of California. Retrieved from

  15. Substance Abuse and Mental Health Services Administration (SAMHSA). (2011). Scope of Practice and Career Ladder for Substance Use Disorder Counseling. Retrieved from

  16. Urada, D., Antonini, V.P., Teruya, C., Tran, E., Huang, D., Padwa, H., Castro-Moino, K., Lee, A.B., & Grossman, J. (2017). California Drug Medi-Cal Organized Delivery System, FY 2016-2017 Evaluation Report. Los Angeles, CA: UCLA Integrated Substance Abuse Programs.

  17. Brassil, M., Backstrom, C., & Jones, E. (2018). Medi-Cal moves addiction treatment into the mainstream: Early lessons from the Drug Medical Organized Delivery System pilots. Oakland, CA: California Health Care Foundation. Issue brief retrieved from

  18. See

  19. See and

  20. See, for example,

  21. See

  22. See

  23. See, for example, Los Angeles County's provider support resources at

  24. A sunrise review is a statutory process that investigates whether there is a need to regulate a previously unregulated profession.

  25. We are grateful to Sherri Daly for sharing the text of the budget request with us.

  26. See

  27. See

  28. See

  29. See

  30. See

  31. New York State Department of Health. (2014). A Plan to Transform the Empire State's Medicaid Program--Better Care, Better Health, Lower Costs: A Multi-Year Action Plan, p. 5 (emphasis in the original text). Retrieved from

  32. See

  33. MRT Action Plan, p. 10.

  34. See

  35. See

  36. See

  37. See

  38. Falcone, A.J., & Berke, D.M. (2018). Medicaid Managed Care Contracting: An Advocacy Guide for State Associations of Behavioral Health Providers. Report prepared for the National Council for Behavioral Health. Retrieved from

  39. See

  40. See

  41. See

  42. See

  43. See

  44. See

  45. See

  46. Chapman, S.A., Blash, L.K., Mayer, K., & Spetz, J. (2018). Emerging roles for peer providers in mental health and substance use disorders. American Journal of Preventive Medicine, 54(6-S3), S267-S274. Retrieved from

  47. See

  48. This term is sometimes used in place of "medication-assisted treatment" to underscore the importance of combining medications with other recovery services such as counseling and peer supports.

  49. See

  50. See

  51. See

  52. See

  53. See