Virginia Expands Gatekeeping of Licensure

Virginia Raises the Bar for New Addiction Treatment Licenses

Virginia has introduced a new gatekeeping step for organizations seeking to open high-priority behavioral health and addiction treatment programs. Beginning November 7, 2025, any applicant pursuing a Priority 1 or Priority 2 service license must complete a state-designed training and pass a proctored Comprehensive Knowledge Exam before their application will be reviewed on the expedited priority timeline.

This requirement comes from the Virginia Department of Behavioral Health and Developmental Services (DBHDS) Office of Licensing and is directly tied to concerns about program quality, compliance, and the operational readiness of new providers entering the system.

For operators planning to start or expand detox, residential, PHP, IOP, or other substance use disorder services in Virginia, this is now a mandatory step if your service type is classified as Priority 1 or 2.

What Exactly Is Required: Orientation Course and Proctored Exam

DBHDS has formalized a two-part process for new Priority 1 and 2 applicants:

Initial Applicant Orientation Training
Proctored Comprehensive Knowledge Exam (85% or higher required)

Initial Applicant Orientation Training

The Initial Applicant Orientation is a structured, self-paced course designed specifically for organizations that want to become DBHDS-licensed providers of Priority 1 or Priority 2 services. Key features:

16 subject-specific modules
- Each module includes a recorded presentation by DBHDS subject-matter experts, a printable slide deck, and a self-assessment quiz.
- Modules must be completed in numerical order because each builds on the last.
Self-assessment quizzes
- There are 15 quizzes (Modules 1–15; no quiz for Module 16).
- Quizzes are untimed and can be retaken as needed.
- You must score at least 85% on each quiz to move forward.
90-day completion window
- All 16 modules and quizzes must be completed within 90 calendar days from starting Module 1.
Who must attend
- At least one participant from each organization must be the Main Authorized Contact (MAC) and/or the owner.
- Participants must be interested in providing a Priority 1 or Priority 2 service and in becoming a DBHDS-licensed provider.

The training is delivered online and accessed through the DBHDS Office of Licensing Initial Applicants section, with quizzes and exam administered via Microsoft Teams.

The Proctored Comprehensive Knowledge Exam

Once all modules and quizzes are completed and documented on the Initial Applicant Orientation Training Checklist, the organization’s representative is eligible for the Comprehensive Knowledge Exam:

Format
- Proctored virtual exam, offered monthly.
- 25 multiple-choice questions.
- 90-minute testing session.
Administration
- Live proctoring via Microsoft Teams; cameras must remain on for the entire exam.
- Admission locks at the scheduled start time; late arrivals must reschedule.
Passing criteria
- Score of 85% or higher required.
- Exam is scored automatically; results are available immediately upon submission.
Prerequisite
- DBHDS must receive and approve the completed Initial Applicant Orientation Training Checklist before exam registration is allowed.

Critically, DBHDS has made this a for priority processing: if an applicant for a Priority 1 or 2 service skips the orientation and exam, the application will not receive priority review and will instead sit on the general waitlist until proof of completion is submitted.

Which Treatment Centers Are Affected?

The new course and exam requirements apply to “Priority 1” and “Priority 2” services as defined by DBHDS in its Priority Service Categories and Review Timelines memo and associated prioritization list.DBHDS+1

While DBHDS has a detailed matrix, at a high level:

Priority services are those the Commonwealth has identified as high-need, high-impact, or high-risk (for example, certain crisis, residential, and intensive behavioral health services).
Many substance use disorder and addiction treatment programs – including detox/withdrawal management and some residential and intensive outpatient levels of care – fall into these categories, depending on the exact service type and regulatory code classification.

For a treatment center operator, the practical step is straightforward:

Check DBHDS’s current Priority Services list to confirm whether your planned ASAM level (e.g., residential SUD, detox, PHP, IOP) is classified as Priority 1 or 2.
If it is, you should assume the Initial Applicant Orientation and Comprehensive Knowledge Exam are mandatory before you submit an initial license application and expect priority processing.

How Treatment Centers Should Prepare: Practical Steps

For PHP, IOP, detox, and residential programs, this new requirement is less a hurdle and more a filter: DBHDS is signaling that only serious, prepared applicants should enter the pipeline. To navigate this efficiently:

a) Designate the right Main Authorized Contact (MAC)

Identify the person in your organization who:

Understands your proposed program model (levels of care, population served, staffing model).
Has authority over policy, operations, and budget.
Is capable of managing the CONNECT Provider Portal and serving as the central liaison with DBHDS.

This MAC or owner should be the one completing the full orientation and exam; they will carry the institutional knowledge into your licensure process and survey prep.

b) Treat the 16 modules as a project, not a checkbox

Given the 90-day window and 16 modules, you should:

Build a simple internal plan or timeline (e.g., 1–2 modules per week).
Print and archive each module’s slide deck and quiz results as part of your licensure documentation file.
Use each module as a prompt to cross-check your policies, floor plans, staffing plans, and budgets against DBHDS expectations.

The orientation covers core topics like licensing definitions, regulatory standards, documentation expectations, and inspection readiness. Leveraging it as a design tool, not just training, will reduce rework later.

c) Align your policies and procedures as you go

As you move through the modules:

Continuously refine your policy and procedure manual to mirror DBHDS language and structure.
Confirm you are aligned with 12VAC35-105 (Rules and Regulations for Licensing Providers) and any service-specific standards that apply to substance use disorder treatment, residential, or intensive services.
Use the DBHDS “Sample Acceptable” and “Sample Unacceptable” policies as calibration tools for format and depth.

This reduces the risk that your policy review will trigger major revisions or delays once your application is under active review.

d) Approach the Comprehensive Knowledge Exam as a readiness test

The exam is a direct proxy for how prepared you are to operate in Virginia’s regulatory environment:

Plan to complete all modules and quizzes well before your preferred exam date to allow time for review.
Use quiz scores and questions that trip you up as a signal for where your organizational plans or policies may be weak.
Schedule the exam at a time when you can ensure an uninterrupted, quiet environment – a failed or incomplete attempt simply pushes your timeline.

Remember: a passing score (85% or higher) is required for your Priority 1 or 2 application to be treated as such.

e) Sequence this with Medicaid and payer strategy

For addiction treatment centers planning to bill Virginia Medicaid under ARTS or contract with MCOs:

DBHDS licensure is a prerequisite to DMAS and MCO credentialing; this orientation and exam are now part of that critical path.
Build the orientation/exam timeline into your go-live schedule and into any pro forma assumptions about when Medicaid revenue begins.
Use the training to validate that your levels of care, ASAM alignment, and staffing ratios will meet both DBHDS and payer expectations.

Key Takeaways for Virginia Addiction Treatment Start-Ups

Virginia’s new course and proctored exam requirement is a clear message: in a tighter regulatory and enforcement environment, the state expects better-prepared operators from day one.

For PHP, IOP, detox, and residential addiction treatment programs, the practical implications are:

If your service type is categorized as Priority 1 or Priority 2, you must complete the DBHDS Initial Applicant Orientation and pass the proctored Comprehensive Knowledge Exam (85%+) before submitting a priority application.
Treat the orientation as a design and readiness process, not just a pre-licensure formality.
Align your policies, staffing, physical plant, and financial planning with what you learn in the modules to reduce survey risk and avoid application delays.
Integrate this new step into your overall project plan for opening or expanding in Virginia; including Medicaid ARTS, commercial payer contracting, and operational go-live.

Transform Your Vision Into a Thriving Behavioral Health Organization

The path to building a successful behavioral health organization isn’t about luck; it’s about precision, foresight, and the right partners at your side. At Atlantic Health Strategies, our team of executives and operators works alongside you to translate vision into reality. We guide mental health, substance use, psychiatric and eating disorder providers through every layer of operational and regulatory complexity; from licensure and accreditation to compliance infrastructure, HR, and IT managed services.

Our approach is hands-on and deeply collaborative. We don’t just advise from a distance; we integrate with your leadership team to build systems that protect revenue, strengthen quality, and sustain growth. Whether you’re opening your first facility or managing a multi-state portfolio, we tailor every engagement to align with your goals, your payers, and your state’s unique regulatory landscape.

If you’re ready to elevate your organization with a partner that understands the business, the compliance, and the mission connect with us today.