Michigan SUD Licensing After June 3, 2026: What LARA Covers

Michigan's amended LARA SUD rules took effect June 3, 2026. See which programs LARA now licenses, what changed for outpatient counseling and what to confirm.

As of October 2026. Michigan rules and bills change, so confirm each point with the Michigan Department of Licensing and Regulatory Affairs (LARA), Bureau of Community and Health Systems (BCHS), before you act on it.

If you run a Michigan substance use disorder organization with more than one level of care, the license map for your sites changed on June 3, 2026. Michigan's amended LARA rules, effective June 3, 2026, list three licensed program categories: methadone, residential and residential withdrawal management. Outpatient counseling, which earlier versions of the rules covered, is no longer one of the listed categories.

That sounds simple. It is not quite. Michigan's licensing statute still reads broadly, a bill that would rewrite it is pending, and some Medicaid documents still describe outpatient and IOP providers as "licensed." For an executive director or compliance lead running a residential program, a withdrawal management unit, a methadone clinic and a few outpatient or IOP sites, the practical job is to map every location to what the current rules say, then confirm the gray areas with LARA.

This article covers facility-level program licensing under Michigan's Public Health Code Part 62 and the LARA rules. It does not cover individual counselor credentials or Medicaid billing details. For the state overview, see the Michigan behavioral health hub.

Quick answer: which substance use treatment programs does Michigan LARA license after June 2026

LARA's Substance Use Disorders Service Program rules (Mich. Admin. Code R 325.1301 to R 325.1399) were amended through 2026 MR 11, effective June 3, 2026. Two provisions carry the change.

First, the definition. R 325.1301(1)(jj) defines a "substance use disorder services program" as an entity offering treatment and rehabilitation services that include "methadone programs, residential programs, and residential withdrawal management programs" (Mich. Admin. Code R 325.1301 to R 325.1399, LARA).

Second, the license itself. Under R 325.1303(6)(d), the license LARA issues identifies the authorized program service categories, and the rule lists only three:

• Methadone program
• Residential program
• Residential withdrawal management program

LARA's BCHS is the bureau that licenses SUD programs, alongside hospitals, nursing homes and other facility types, and it handles inspections, complaint investigations and enforcement (LARA Bureau of Community and Health Systems). If your binder still says SUD program licensing sits with MDHHS, update it: R 325.1301(1)(h) defines "department" in these rules as LARA.

What changed for outpatient counseling programs and branch offices

LARA said plainly what it intended. Its notice of a February 19, 2026 public hearing on rule set 2025-31 LR says the proposed rules would "deregulate outpatient counseling programs which also eliminates need for branch offices" (Michigan Register, 2026 Issue 2). The same notice lists two other changes: allowing self-administration of non-SUD medications for acute and chronic conditions, and removing the requirement that a methadone patient have an opioid disorder diagnosis for at least one year before admission.

The final rule text matches that intent. The amended R 325.1301 to R 325.1399 no longer lists outpatient counseling as a license category, and the branch office provisions are gone. Mobile units remain: R 325.1304 still sets out an application process for a mobile unit, with a licensed methadone program as the parent organization under R 325.1304(3), and R 325.1303(1) still lists adding or deleting a mobile unit as a licensure change.

Two things did not change, and they matter for how you describe your outpatient sites:

1. The statute. 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" without a Part 62 license (MCL 333.6233, Michigan Legislature). The narrowing to three categories comes from the rule definition, not from a change to that statutory text.
2. R 325.1303(2). The rule still says an individual offering SUD services shall be licensed under article 6, subject to the exception in R 325.1303(3) for licensed professionals practicing within their own license and not under a group offering SUD services.

So the careful reading is this. LARA's amended rules define a licensed program as methadone, residential or residential withdrawal management, and LARA describes the change as deregulating outpatient counseling programs. That is not the same as a written statement that no approval of any kind applies to your outpatient or IOP site. Before you let an outpatient license lapse or tell a payer it no longer exists, get LARA BCHS's answer for that specific site in writing.

What did not change for residential, withdrawal management and methadone sites

For the three licensed categories, the core licensing mechanics under R 325.1303 carry forward:

• Application on LARA's form. Under R 325.1303(1), an application for initial licensure or a licensure change, including change of ownership, change of business name, relocation, addition or deletion of service levels, or a mobile unit, is made on the current LARA form.
• Completeness review. Under R 325.1303(4), LARA notifies an applicant in writing within 30 days if an application is incomplete, and an application is not complete until the form, attachments and fee are in.
• Prelicensure survey. Under R 325.1303(5), LARA makes a determination within 3 months after a complete application, and a prelicensure survey applies to residential, residential withdrawal management and methadone programs. R 325.1303(5) also says only an application review is required for any other program, one more reason to ask LARA how it treats an outpatient site.
• Post-licensure survey. Under R 325.1303(7), LARA conducts a post-licensure survey within 3 months after an initial license is issued.
• No transfers. Under R 325.1303(9) and (10), a license is not transferable. LARA issues a new license before a change of ownership or a move from one physical location to another.

The residential withdrawal management definition, R 325.1301(1)(gg), still covers a residential setting offering either clinically managed or medically monitored withdrawal management. If you think about these services in ASAM terms, our guide to ASAM levels of care explains the clinical framework, but the Michigan license category is what LARA puts on the license.

The amended rules also keep a naloxone protocol. Under R 325.1331, a program's policy on naloxone access includes a protocol to offer a naloxone kit to, at a minimum, all recipients with a history of opioid use or otherwise at risk for overdose.

For residential operators, the operational side of this (beds, census, admissions) is covered in our residential treatment overview.

The 2023 rule changes the 2026 amendments build on

Michigan's SUD rules were last overhauled in 2023. LARA's 2023 FAQ says the revised rules took effect June 26, 2023, and that round added branch offices and mobile units, required programs to offer naloxone to recipients with a history of opioid use, and folded clinically managed withdrawal management into the residential withdrawal management category.

The 2023 FAQ is still online, and that is a trap for anyone building a policy manual from it. It says a branch office "cannot be open to program recipients more than 20 hours per week" (LARA 2023 SUD Rule Changes FAQs). It also describes limited certified counselor caps of 32 recipients for outpatient counseling or methadone services and 10 for residential or residential withdrawal management services. The branch office items and the outpatient counseling part of that cap describe the 2023 rules, and the amended 2026 rule text contains neither.

What still lines up between the FAQ and current text is narrower: the naloxone offer, mobile units (now tied to a licensed methadone program as the parent organization), the limited certified counselor caps for methadone programs (R 325.1383(6)) and residential settings (R 325.1385 and R 325.1388), and clinically managed withdrawal management sitting inside the residential withdrawal management category. Treat the FAQ as history, and cite the current rule text for anything you put in a policy.

Pending Michigan legislation: House Bill 5729

The statute itself may change. House Bill 5729 of 2026 addresses "persons required to hold a substance use disorder services program license" and would amend MCL 333.6230, 6233, 6234 and 6238 (House Bill 5729 of 2026, Michigan Legislature). It is part of a package with House Bills 5728 and 5730 to 5738.

According to the bill page, it was introduced March 18, 2026, referred to the Committee on Health Policy, and on June 24, 2026 was reported with a recommendation for referral to the Committee on Rules. As of October 2026 it has not been enacted. The bill text linked from that page is the introduced version, so read the current version there before relying on any summary of what it would change.

For planning, the point is simple: the outpatient picture could shift again if the package moves. Re-check the bill page before you make a licensing decision that would be hard to reverse, such as surrendering a license.

Why Medicaid code charts still say "licensed" for IOP and outpatient

Michigan's Medicaid specialty behavioral health system did not rewrite its documents on June 3. The MDHHS SFY 2027 code chart lists H0015 (SUD intensive outpatient, 9 to 19 hours of structured programming per week) with the qualification text "Provider agency licensed and accredited as substance abuse treatment program" (MDHHS SFY 2027 Behavioral Health Code Charts and Provider Qualifications). Similar language appears on other outpatient SUD codes.

The sources available as of October 2026 do not say how MDHHS or the regional PIHPs will read that wording for an outpatient or IOP site that LARA's rules no longer list as a license category. This article does not answer that question, and neither should your team on its own. Ask your PIHP contract manager directly, in writing, what they expect to see for each outpatient and IOP site, and keep the answer with your licensing file.

Checklist: map every Michigan site to a license category and a payer expectation

For a multi-site Michigan organization, a one-page site map heads off most of the confusion. For each location:

1. List the services delivered there. Methadone, residential, residential withdrawal management, outpatient counseling, IOP, PHP, mobile unit.
2. Match each service to the R 325.1303(6)(d) categories. Methadone, residential and residential withdrawal management sites map to a license category under the amended Michigan rules.
3. Flag every outpatient and IOP site. Write to LARA BCHS and ask how the amended rules apply to that site, given MCL 333.6233 and R 325.1303(2). File the reply.
4. Retire branch office references. Pull the 20-hour branch office limit and the 2023 FAQ's outpatient counseling items out of policies that now point to superseded text.
5. Check payer documents separately. Note what each PIHP contract and the MDHHS code chart say about licensure for that site's codes, and get written direction where they conflict with the rule change.
6. Plan ownership and moves early. Under R 325.1303(10), a change of ownership or relocation needs a new Michigan license first, so build the application and survey windows into deal and lease timelines.
7. Watch House Bill 5729. Set a reminder to re-check the bill page each quarter.

Groups operating in several states run into the same pattern elsewhere, where each state draws license categories differently. Our piece on EHR needs for multi-state behavioral health groups covers how that plays out operationally. For staff who cover more than one Michigan site, our guide to testing multi-location EHR permissions shows how to check what each role can see and do at each location.

How Ease fits a multi-site Michigan program map

Ease runs multi-state, multi-location groups on one instance, with each location carrying its own state, NPI, billing provider and levels of care. Admins configure which sites offer each level of care, so clinicians at a residential site and an outpatient site see the options that apply to them. That keeps the site map above in the same system your staff schedule and chart in, while the licensing calls themselves stay with LARA and your payers.

Key takeaways

• Since June 3, 2026, Michigan's LARA rules list three license categories: methadone, residential and residential withdrawal management.
• LARA describes the change as deregulating outpatient counseling programs and eliminating the need for branch offices.
• MCL 333.6233 and R 325.1303(2) still read broadly, so confirm outpatient and IOP sites with LARA BCHS in writing.
• The 2023 FAQ's branch office and outpatient counseling items are out of date.
• MDHHS code charts still use "licensed and accredited" wording for outpatient SUD codes, so ask your PIHP.
• House Bill 5729 could change the statute again. Check it before any irreversible licensing step.

Frequently Asked Questions

Which substance use disorder program categories does Michigan LARA license after June 3, 2026?

Under the amended LARA rules (Mich. Admin. Code R 325.1303(6)(d), effective June 3, 2026), a license authorizes three program service categories: methadone program, residential program and residential withdrawal management program.

Does an outpatient or IOP site in Michigan still need a LARA license?

The amended rules define a licensed program as methadone, residential or residential withdrawal management, and LARA's own hearing notice describes the change as deregulating outpatient counseling programs. MCL 333.6233 still reads broadly, though, so confirm each outpatient and IOP site's status in writing with the LARA Bureau of Community and Health Systems.

Do Michigan SUD programs still use branch offices?

LARA's February 2026 hearing notice says deregulating outpatient counseling also eliminates the need for branch offices, and the amended rule text no longer contains branch office provisions. The 2023 FAQ that describes branch office hour limits explains the 2023 rules and is out of date on that point.

Does a change of ownership or a move need a new Michigan SUD license?

Yes. Under Mich. Admin. Code R 325.1303(9) and (10), a license is not transferable, and LARA issues a new license before a transfer to a new owner or a move from one physical location to another.

Is there pending Michigan legislation that could change SUD program licensing again?

House Bill 5729 of 2026 would amend MCL 333.6230, 6233, 6234 and 6238 on who must hold a SUD services program license. It was reported from House Health Policy on June 24, 2026 with a referral to the Rules committee and was not law as of October 2026.