Virginia DBHDS License for SUD and Mental Health Programs

Virginia DBHDS licensing for SUD and mental health programs in 2026: priority list, TRAIN orientation, 85% exam, CONNECT, the 90-day window and license types.

As of October 2026. Virginia's priority list, orientation process and licensing chapter have all changed in the past 18 months, and DBHDS is restructuring 12VAC35-105. Section numbers below were checked on October 27 to 29, 2026; confirm them before you file.

In Virginia, the service you apply for decides how fast DBHDS reviews your license application: Priority 1 services are assigned to policy review within 5 to 10 business days, Priority 2 within 21 business days, and non-priority services wait on a list that releases at least one applicant a month. That ranking, plus a mandatory orientation and proctored exam for priority services, now shapes the opening timeline for any residential, PHP, IOP, crisis or opioid treatment program in the Commonwealth more than the application paperwork itself.

This guide is for the executive director, COO or compliance lead planning a new Virginia program, often as one site in a multi-state group. For the wider Virginia picture, including Medicaid and the managed care plans, start at our Virginia state hub.

In short: how do I get a substance abuse treatment facility license in Virginia?

The steps, in order:

1. Find each service you plan to offer on the DBHDS Prioritization List and note its priority level.
2. For a Priority 1 or Priority 2 service, create a TRAIN account, finish the 16 orientation modules and self-assessments, and request a seat at the proctored exam.
3. Pass the Comprehensive Knowledge Exam with 85% or higher, or at least have your exam date confirmed.
4. Gather the application documents (budget, working capital proof, staffing plan, credentials, service description, records management policy) before you open the online application.
5. Open and submit the application in the DBHDS CONNECT Provider Portal within 90 days.
6. Wait for assignment to a policy review specialist, answer any deficiency letters on time, and complete the review.
7. Receive a conditional license, then work toward an annual or triennial full license.

DBHDS describes CONNECT as the portal where applicants "submit new applications and license modifications, track application status, review the waitlist" (DBHDS Licensing Information for Providers and Applicants). Every step from here runs through that portal.

Which services DBHDS licenses and where ASAM levels fit

Virginia licenses providers by service, not by building. 12VAC35-105-30 lists 33 licensed services, and the ones most facility operators care about include clinically managed residential care at Levels 3.1, 3.3 and 3.5, medically monitored intensive inpatient at Level 3.7, medically managed intensive inpatient at Level 4.0, substance abuse intensive outpatient and partial hospitalization, mental health intensive outpatient and partial hospitalization, residential treatment, crisis stabilization units, crisis receiving centers and medication for opioid use disorder treatment.

The license addendum is where the detail lives. Under 12VAC35-105-30(C), the addendum describes each licensed service, the disabilities of the people you may serve, the specific locations and the terms and conditions; for residential and inpatient services, the license identifies "the number of individuals each residential location may serve at a given time" (12VAC35-105-30). Plan bed counts per site before you apply, because capacity is written into the license itself.

Each service is its own line on the application, so a campus running Level 3.5, Level 3.1 step-down and an IOP files for three services. The ASAM level labels in Virginia's rule follow the older numbered levels; our explainer on ASAM levels of care walks through how those map to the Fourth Edition.

Priority 1, Priority 2 and non-priority: how your service type sets your timeline

DBHDS sorts initial applications into three groups. In its July 2025 memo, the Office of Licensing defined Priority 1 as "essential services with a significant unmet need statewide" (DBHDS memo, July 18, 2025). Priority 2 services are adequately available in some areas but still benefit from development, and non-priority services either do not match current Commonwealth priorities or are already widely available.

The same memo set the review clocks: Priority 1 assignment to policy review in 5 to 10 business days, Priority 2 in 21 business days, and at least one non-priority applicant pulled from the waitlist each month. Priority 1 and 2 reviews were streamlined toward potential licensure within 90 days of a complete application; non-priority applications are reviewed in the order received and may see significant delays.

Here is where common facility services sit on the DBHDS Prioritization List revised 09/16/2026 (DBHDS Prioritization List):

The list moves. In the July 2025 memo, the adult and youth crisis stabilization units were Priority 2 and the 23-hour crisis receiving centers were Priority 1; on the 09/16/2026 list all four are Non Priority. If your business plan assumed a crisis unit would clear review on the priority timeline, re-check the current list before you commit to a lease or a hiring plan.

One more rule from the July 2025 memo matters for groups that already filed: a DBHDS applicant waiting on a non-priority application who wants to apply for a Priority 1 or 2 service has to withdraw the waitlisted application before submitting a new one.

The Initial Applicant Orientation and the 85 percent exam

Since November 7, 2025, Virginia's DBHDS has required any applicant submitting a new application for a Priority 1 or Priority 2 service to complete the Initial Applicant Orientation and pass the proctored Comprehensive Knowledge Exam with a score of 85% or better. The October 2025 memo is blunt about the consequence: applications filed without it "will not be reviewed under the priority timeline" (DBHDS memo, October 23, 2025). They go to the waitlist with non-priority services until DBHDS receives proof of completion.

The delivery changed in 2026. A DBHDS memo dated April 27, 2026 moved the orientation into the TRAIN learning management system, available from May 26, 2026, and stopped accepting the old orientation checklist on May 8, 2026. The memo notes the training materials are now "accessible in TRAIN; no longer available on the OL website" (DBHDS memo, April 27, 2026). The sequence now runs:

1. Create a TRAIN account and search for the course under DBHDS: Office of Licensing.
2. Complete all 16 modules and their self-assessments.
3. Email the Comprehensive Knowledge Exam Registration Request form, with a copy of a government-issued photo ID, to the Office of Licensing.
4. Once approved, use the registration link to sign up for an exam date.

The 2026 exam runs once a month with a morning and an afternoon session, and the remaining 2026 dates are November 19 and December 10. DBHDS also warns that a participant who fails the exam three times will "wait six months before they are eligible to register to retake" (2026 Comprehensive Knowledge Exam Dates). For a group with a fixed opening date, that retake rule is the biggest scheduling risk in the whole process.

On timing, the DBHDS memos say the training comes before the application begins. The DBHDS licensing page adds a practical recommendation: do not start the online submission "until you have completed training and are scheduled for the exam," or until you have passed it (DBHDS Licensing Information for Providers and Applicants). Passing first is the safer path, because the 90-day clock starts when you begin.

What the CONNECT application needs: budget, 90 days of working capital, staffing plan, records policy

12VAC35-105-40 sets the core package for a provider that is not yet licensed in Virginia. At the provider level, the rule calls for:

• A first-year working budget with projected revenue and expenses, including a revenue plan.
• Documentation of working capital: for a corporation, partnership, sole proprietor or unincorporated organization, the rule asks for funds or a line of credit "sufficient to cover at least 90 days of operating expenses" (12VAC35-105-40).
• Documentation of authority to do business in Virginia.
• A disclosure statement listing services you hold or have held licenses for in Virginia or other states, prior sanctions or negative actions, and disciplinary actions.

Then, for each service on the application:

• A staffing plan.
• Employee credentials and job descriptions with the elements in 12VAC35-105-410(A).
• A service description with the elements in 12VAC35-105-580(C).
• A records management policy with the elements in 12VAC35-105-390 and 12VAC35-105-870(A).

DBHDS posts an Application Document Matrix, sample policies and a sample operating budget on its licensing page. For a multi-state operator, the disclosure statement usually takes longest, since it covers every license the entity has held anywhere.

The 90-day window, the waitlist and what happens to an incomplete application

DBHDS applies a hard clock to the online application. Initial and modification applications not submitted within 90 days of beginning the process are administratively closed, and the applicant restarts. The April 2026 memo ties the clock to the date the application is created in CONNECT.

After submission, every application to Virginia's Office of Licensing lands on a waitlist you can view in CONNECT. DBHDS says applications "may not be processed in chronological order" because state initiatives can shift prioritization (DBHDS Licensing Information for Providers and Applicants). Once you are assigned to a policy review specialist, answer deficiency letters within the stated timeframe; the July 2025 memo warns that failing to respond may close the application and force a new one.

If your area lacks a non-priority service, the July 2025 memo lets you send supporting data to the relevant DBHDS Assistant Commissioner and ask for reclassification. Do not build a launch date on that request.

Conditional, provisional and full licenses: what each lets you do

12VAC35-105-50 defines three license types, and a new program starts at the first one.

• Conditional. Issued to a new provider that shows compliance with administrative and policy regulations but not yet all regulations. It lasts up to six months, and with renewals cannot exceed 12 successive months. A provider on a conditional license cannot add services or locations during that period, and a group home or community residential provider is limited to one location serving no more than four people.
• Provisional. Issued to a provider that has shown it cannot maintain compliance, for example after human rights or licensing violations. It also runs six months, 12 with renewals, and the provider cannot increase services, locations or capacity.
• Full. Issued once a provider shows compliance with all applicable regulations, for up to three years (triennial) or one year (annual). Under 12VAC35-105-50, the first full renewal after a conditional or provisional license "shall not exceed one year" (12VAC35-105-50).

Two more rules from the same section affect growth plans. A Virginia license cannot be transferred or assigned, so a change in ownership means a new application and a new license. And if you file a renewal before expiration and there are no grounds to deny it, the license stays in effect, with DBHDS issuing a letter extending it six months if the renewal is not yet issued.

For a multi-site group, the conditional period is the planning constraint: you cannot add the second location or the step-down level until you hold a full license, so sequence your openings around it. When the second site does open, check which staff can view and act on each location's work in your EHR before go-live; the multi-location EHR permission test cases guide lays out how.

After the license: Medicaid enrollment and plan contracting

A DBHDS license is the starting document for Virginia Medicaid, not the end of the process. Medicaid enrollment runs through the DMAS Provider Services Solution (PRSS), and contracting runs separately with each Cardinal Care managed care plan. DMAS warns that MCOs and DMAS are "prohibited from paying claims to network providers who are not enrolled in PRSS" (DMAS bulletin, August 20, 2026), and asks providers to keep license information current for every service location. We cover ARTS residential billing in a separate Virginia guide.

DBHDS is also mid-way through restructuring its licensing rules. Its August 2025 memo said the single chapter will become a General chapter plus five service-specific chapters, through a process that "usually takes up to two years" (DBHDS memo, August 25, 2025). Section numbers in this guide may move when the new chapters take effect.

Where Ease fits

Ease keeps one chart for each patient as they move between the levels of care your organization offers. Each organization configures which levels of care it offers, and each patient's placement carries admission, transfer and discharge statuses. Residential programs get a per-location bed board with projected availability based on each occupant's estimated discharge date, a useful view to keep beside the capacity your license addendum lists (more in our piece on bed management and census for residential behavioral health). Multi-site groups run every location on one instance, each with its own NPI and billing provider, and admins configure which sites offer each level of care; see EHR for multi-state behavioral health groups and our residential treatment solution. Licensing decisions stay with DBHDS.

Questions to put to DBHDS before you apply

Send these to the Office of Licensing in writing and keep the replies in your licensure file:

• Is each service we plan to offer still at the priority level shown on the current Prioritization List, and when was the list last revised?
• Does our orientation completion cover every Priority 1 and 2 service on our application, or does each applicant entity need its own completion?
• Which exam date can we confirm before we open the CONNECT application?
• For a campus with several levels of care, how should the staffing plan and service descriptions be split across services?

Frequently Asked Questions

Which agency licenses substance use and mental health treatment programs in Virginia?

The Office of Licensing at the Virginia Department of Behavioral Health and Developmental Services (DBHDS) licenses them under 12VAC35-105. That chapter lists the services DBHDS licenses, including ASAM Levels 3.1, 3.3, 3.5, 3.7 and 4.0, substance abuse intensive outpatient and partial hospitalization, medication for opioid use disorder treatment, crisis stabilization units and crisis receiving centers. Applications, renewals and modifications go through the DBHDS CONNECT Provider Portal.

Do I have to pass an exam before applying for a Virginia DBHDS license?

For a Priority 1 or Priority 2 service, yes. Since November 7, 2025, Virginia's DBHDS has required applicants for those services to complete the Initial Applicant Orientation and pass the proctored Comprehensive Knowledge Exam with 85% or higher. Since May 26, 2026 the 16 modules run in the TRAIN learning system. A priority application filed without proof of completion goes to the waitlist with non-priority services.

How long does DBHDS take to review a new license application?

It depends on the service's priority level on the DBHDS Prioritization List (revised 09/16/2026 as of this writing). Under the July 2025 DBHDS memo, Priority 1 applications are assigned to policy review within 5 to 10 business days and Priority 2 within 21 business days, with potential licensure within 90 days of a complete application. Non-priority applications wait on a list that releases at least one applicant a month.

What happens if I do not submit my CONNECT application within 90 days?

DBHDS administratively closes initial and modification applications not submitted within 90 days of beginning the process, and the applicant restarts. That is why DBHDS recommends finishing orientation and scheduling or passing the exam before you open the online application.

What is a conditional license in Virginia?

Under 12VAC35-105-50, a conditional license is the first license a new provider can receive when it shows compliance with administrative and policy regulations but not yet all regulations. It lasts up to six months, cannot pass 12 successive months with renewals, and the provider cannot add services or locations during that period.