California's Mandatory Outpatient SUD Certification

Until recently, an outpatient substance use disorder (SUD) program in California could operate without any state credential at all. Certification by the Department of Health Care Services (DHCS) was voluntary, and DHCS itself wrote that many outpatient programs "were not subject to any governmental oversight" (Behavioral Health Information Notice 25-003, February 3, 2025). Assembly Bill 118 ended that. It added Chapter 7.1 to the Health and Safety Code, beginning at Section 11832, and made DHCS certification mandatory for outpatient programs that offer treatment, recovery, detoxification or medication for addiction treatment services.

Have the AB 118 deadlines passed?

Yes. According to BHIN 25-003, any non-exempt program had to submit an Initial Application for Certification (form DHCS 6040) by January 1, 2024, and had to obtain certification by January 1, 2025. Programs already certified under the old voluntary system are treated as certified under Chapter 7.1 until the expiration date on their current certificate (H&S Code 11832.24, as described in the BHIN).

A program opening now simply needs certification before it starts. There is no grace period for new programs.

What happens to a program that operates without certification?

Section 11832.18 lays out the process. If a program is alleged to be operating without certification, DHCS conducts a site visit. If it finds the program providing treatment, recovery, withdrawal management or medication-assisted treatment services without certification, it issues a written notice that sets a date by which the program must stop. From there:

• DHCS may assess a civil penalty of up to $2,000 for every day the program keeps providing services past that date.
• The case may be referred for civil proceedings.
• The person or entity is barred from applying for initial certification for five years from the date of the notice.

The five-year bar is the part operators tend to miss. An uncertified program that is caught does not simply pay a fine and apply; it can lose the ability to apply at all for half a decade.

Who is exempt from DHCS certification?

Section 11832.3(b) exempts programs operating in these settings, which may still seek certification voluntarily:

• adult alcoholism or drug abuse recovery or treatment facilities, driving-under-the-influence programs and narcotic treatment programs licensed by DHCS;
• clinics and health facilities licensed by the Department of Public Health;
• community care facilities, residential care facilities for persons with chronic life-threatening illness, residential care facilities for the elderly and adult day health care centers licensed by the Department of Social Services;
• public elementary and secondary schools; and
• county jails and state correctional institutions, including juvenile justice facilities.

BHIN 25-003 adds two more. An individual health care practitioner licensed under Division 2 of the Business and Professions Code, acting within the scope of that license, does not need DHCS certification. Indian Health Care Providers enrolled as Medi-Cal providers are not required to obtain certification if they meet all applicable standards.

The practitioner exemption is narrow. It covers a licensed clinician practicing within their own license, not a business that employs clinicians to run a program. If you are a group practice wondering which side of that line you are on, look at how the services are organized and billed, not just at who delivers them. For the clinician side, see White Glove Counseling's guide to the California LPCC for counselors already licensed in another state.

Which forms make up the application?

By statute, an applicant submits a complete written application, a certification fee, an initial application fee and any other documentation DHCS specifies (H&S Code 11832.4). DHCS may then issue certification after an onsite review and a determination that the applicant can comply (11832.5(a)). DHCS terminates review of an application that is incomplete or whose applicant had a DHCS certification or residential license revoked within the previous five years (11832.5(b)).

The forms incorporated into DHCS's certification standards, as listed in BHIN 25-003, give a good picture of the file:

• Initial Application for Certification (DHCS 6040), or DHCS 6041 for an existing certified program adding a new program
• Disclosure to DHCS (DHCS 5140)
• Staff and Health Care Practitioner Information (DHCS 5050) and Program Director Information (DHCS 5082)
• Administrative Organization forms (DHCS 5083 or 5084) and Designation of Administrative Responsibility (DHCS 5085)
• Schedule of Recovery and Treatment Services (DHCS 5086)
• Health Questionnaire and Screening (DHCS 5103), plus the detoxification observation logs (DHCS 6045 and 6046) for programs offering detox
• Incident, Injury or Death Report (DHCS 5079)

DHCS accepts applications through its Licensing and Certification Portal or by email, and asks applicants seeking both a residential license and certification to send everything as one package. DHCS also announced a fee increase for licensure and certification beginning July 1, 2026 (BHIN 26-004), so confirm the current amounts in the application before paying.

What does a certified program have to report?

Section 11832.11 requires a certified program to report a death at the program, an injury to a client that requires emergency medical treatment, reportable communicable disease, natural disasters and fires or explosions on the premises; BHIN 25-003 sets the deadline at one working day. Programs must also notify DHCS in a timely manner of changes to their organizational structure, contact details or operating days and hours, including any planned temporary pause.

Certified programs that break the rules face their own penalty scale. Apart from suspension or revocation, DHCS may levy civil penalties of $250 to $500 a day per violation, up to $1,000 a day, and repeat violations within 24 months carry higher daily amounts (11832.20). DHCS must give notice and a chance to correct first.

How often does certification renew?

Certification runs for two years. DHCS's program certification page says a certified provider must submit the renewal application (DHCS 6043), the biennial fees and required information at least 90 days before the certification expires, and that missing that deadline results in automatic termination at the end of the two-year period. Ninety days is a long lead time; it is the date most worth putting on a renewal calendar.

Does a residential program need outpatient certification too?

A DHCS-licensed residential facility is exempt from outpatient certification under 11832.3(b)(1), although it may seek certification voluntarily. Residential licensing has its own rules, including a level of care requirement; see California's residential AOD license and level of care designation.

How can we help with California certification?

We prepare the DHCS 6040 package and every supporting form, write or adapt your policies to DHCS's Alcohol and Other Drug Certification Standards, and get you ready for the onsite review. Your owner or officer signs the forms and pays DHCS, and the portal account stays yours. Our State License package for an outpatient program is $1,995 per site, including IOP components, and Renewal Tracking is $299 a year per certificate so the 90-day deadline never slips. Details for other states are on the California licensing page and the state index.