March 12, 2023

FYI re:  our communication to members sent Friday (linked here), it is noteworthy that, at the present time under the current Licensure Threshold regulations, an Article 28 D&TC cannot provide substance use disorder (SUD) services without being certified by OASAS, pursuant to MHL Article 32 (except as permitted by scope of practice of individual practitioners).

There is one exception to this regulation:

Under DSRIP Project 3.a.i Licensure Threshold, OASAS implemented a Licensure Threshold for DSRIP providers participating in project 3.a.i so that Article 28 D&TC providers could provide up to 49% of its total annual visits for substance use disorder services without MHL Article 32 certification.  

The Department of Health intends to reconstitute an integration workgroup to revise regulations and develop a mechanism to preserve the flexibilities granted by DSRIP 3ai waivers, in anticipation of the current waiver end date in 2025.  This will be one of several charges for the new workgroup.