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The Short Answer: Two New Hurdles Before You Can File a Priority Application
Effective November 7, 2025, the Virginia Department of Behavioral Health and Developmental Services (DBHDS) requires every applicant pursuing a Priority 1 or Priority 2 service license to complete a 16-module Initial Applicant Orientation and pass a proctored Comprehensive Knowledge Exam with a score of 85% or higher before the application will be reviewed on the priority timeline. Skip either step and your file gets pushed onto the general waitlist behind non-priority services. DBHDS Commissioner Nelson Smith’s Office of Licensing issued the memo in October 2025, and the materials went live on the OL website by November 1, 2025.
This is a real filter, not a paperwork formality. Applicants who submit without proof of completion will not be reviewed under the priority timeline and instead get placed on the waitlist with non-priority services and pulled in the order in which the application was received. For SUD operators planning detox, residential, PHP (which is outpatient, ASAM Level 2.5), or IOP services in Virginia, the orientation-and-exam step is now part of the critical path to licensure, DMAS enrollment under ARTS, and MCO contracting. CARF and Joint Commission accreditation surveys come later, but operators who fail this DBHDS gate never get to the survey window.
What DBHDS Is Actually Requiring
The new structure has two gates. First, the orientation. The orientation consists of 16 self-paced modules, and each module has a video presentation and a self-assessment quiz. Quizzes are untimed, can be retaken, and require an 85% to advance. All 16 modules must be completed within 90 calendar days of starting Module 1, and at least one participant per organization must be the Main Authorized Contact (MAC) or the owner.
Then the exam. The exam consists of 25 multiple-choice questions, and you must score 85% or higher to pass. The exam is scored automatically at completion, so you know immediately. It runs 90 minutes, is proctored live over Microsoft Teams with cameras on the entire time, and admission locks at the scheduled start. Late arrivals reschedule, period. Submitting the Initial Applicant Orientation Checklist is required before you can register for the Comprehensive Knowledge Exam and officially complete the Initial Applicant Orientation Training.
DBHDS framed the purpose plainly in its October 2025 memo: “Promote consistent, quality services delivered by knowledgeable and prepared providers.” Translation for operators: the state is tired of vetting underprepared applicants and is moving the screening upstream.
Which SUD Services Are Caught by Priority 1 and Priority 2
DBHDS sorts services into three buckets. Services are divided into three categories based on priority. The services highlighted in green are Priority 1 Services and the services highlighted in blue are Priority 2 Services. Services not highlighted are Non-Priority Services. Priority 1 Services are essential services with significant unmet need statewide, and DBHDS prioritizes the development and licensing of these services.
Why so aggressive on supply? Look at the demand side. The Virginia Department of Health logged 18,292 drug overdose emergency department visits in 2024, a 16% decrease from 2023, and 420 Virginia infants younger than one year hospitalized with Neonatal Abstinence Syndrome (NAS), a 10% increase from 2023. The pipeline pressure on residential withdrawal management (ASAM Level 3.7 under the 4th Edition), residential SUD, and intensive outpatient capacity is not theoretical. The Commonwealth wants more licensed providers, but only ones who can actually operate at the level CMS, SAMHSA, and the Virginia Department of Medical Assistance Services (DMAS) expect once Medicaid claims start flowing.
The processing timelines tell you what is on the line. Priority 1 services will be assigned within 5–10 business days; Priority 2 services within 21 business days; and for non-priority services, at least one applicant will be removed from the waitlist and assigned to policy review each month. For non-priority services it could take a year or longer to become licensed. The orientation-and-exam gate is what stands between you and the 5-to-21-business-day lane.
How Operators Should Sequence This (From Someone Who Has Walked Clients Through It)
Treat the 16 modules as a design exercise, not a checkbox. The orientation walks through eligibility, provider responsibilities, the application phases, and the regulatory frame under 12VAC35-105. Use each module as a prompt to stress-test your policy manual, staffing plan, physical plant, and budget against the language DBHDS uses. The DBHDS “Sample Acceptable” and “Sample Unacceptable” policies are calibration tools, use them.
Pick your MAC carefully. This person should understand the proposed level of care, hold real authority over policy and budget, and be willing to own the CONNECT Provider Portal as the central liaison with DBHDS. Whoever sits the exam is also the person carrying institutional memory into survey prep and your first EOC tour. Do not delegate this to a contractor who will leave after licensure. We have watched operators in Tennessee and Florida regret that choice when the surveyor focus shifts mid-application and there is no one inside the building who actually understands the regulations.
Sequence the payer track in parallel, not after. Virginia’s Medicaid Program launched the enhanced substance use disorder treatment benefit, Addiction and Recovery Treatment Services (ARTS), on April 1, 2017. Providers must submit a DBHDS license for the intended level of care to the DMAS Provider Services Solution (PRSS) vendor and each of the Medicaid health plans to start the credentialing and contracting process. Your pro forma assumptions about when Medicaid revenue actually begins should now include the orientation, the exam, the priority review window (5–21 business days for assignment), and DMAS plus MCO credentialing on the back end, which routinely runs 90 to 120 days per plan. If your model assumes first ARTS revenue at month four, rebuild it.
One more sequencing point. Initial Applications and Modification Applications must be submitted within 90 days of beginning the application process. The clock is real. Plan the exam date around when your policies, attachments, and staffing documentation will actually be ready for submission, not when the orientation finishes.
What This Tells You About Where Virginia Is Heading
Virginia is doing what a handful of states have started doing quietly: raising the floor on who gets to enter the behavioral health system. DBHDS oversees the licensing and regulation of more than 1,000 providers across the Commonwealth, and demand still outstrips supply in most regions for SUD residential and withdrawal management beds. Rather than open the gates wider, DBHDS is narrowing the gate and grading on preparedness before anyone touches a license number. This mirrors what we are watching the DEA do with new buprenorphine prescriber oversight and what the HHS Office of Inspector General has signaled on behavioral health enrollment fraud.
For operators we work with in Virginia, the takeaway is unglamorous. Founders and CEOs who treat the orientation as a design tool finish licensure faster, with cleaner policies and fewer policy-review revisions. Founders who treat it as a hurdle to clear with the cheapest available warm body lose months on the waitlist and rework. The orientation is now the cheapest mock survey you will ever get from DBHDS. Use it.
If you are weighing Virginia against other states for your next site, run the math honestly. A Priority 1 service assigned in 5–10 business days is still one of the more predictable timelines on the East Coast, as long as your MAC passes the exam on the first attempt. A failed exam plus a re-test window plus a 90-day application clock can push a planned January go-live to May, and at roughly $80,000 to $120,000 per month in pre-revenue burn for a mid-sized residential SUD startup, that delta is the difference between a workable pro forma and a capital call.
Frequently asked questions
When does the new DBHDS orientation and exam requirement take effect, and who has to comply?
The requirement took effect November 7, 2025. Any applicant submitting a new application for a Priority 1 or Priority 2 service through DBHDS must complete the Initial Applicant Orientation Training and pass the proctored Comprehensive Knowledge Exam with a score of 85% or higher. The orientation materials were posted to the DBHDS Office of Licensing website by November 1, 2025.
What happens if my organization submits a Priority 1 or 2 application without completing the exam?
Per the October 2025 DBHDS memo, applications submitted without proof of completion will not be reviewed under the priority timeline. They get placed on the waitlist with non-priority services and pulled in the order received, which historically can mean a year or longer to license under the non-priority track.
How does the orientation timeline affect Virginia Medicaid ARTS enrollment?
DBHDS licensure is a prerequisite to DMAS enrollment under the ARTS benefit. DMAS requires providers to submit the DBHDS license for the intended level of care to the Provider Services Solution (PRSS) vendor and each Medicaid health plan before credentialing and contracting can start. The orientation-and-exam step now sits on the critical path between feasibility and your first ARTS-reimbursed claim, and it should be reflected in your pro forma revenue ramp, especially given that MCO credentialing routinely runs another 90 to 120 days per plan.
What exactly does the Comprehensive Knowledge Exam look like?
It is a 90-minute proctored virtual exam delivered through Microsoft Teams with cameras required on for the full session. It contains 25 multiple-choice questions, requires 85% or higher to pass, and is scored automatically at submission. You cannot register for the exam until DBHDS has received and approved your completed Initial Applicant Orientation Training Checklist.
References
- Virginia DBHDS Office of Licensing, Licensing Information for Providers and Applicants
- DBHDS Memo: Initial Applicant Orientation for Priority 1 and Priority 2 Services (October 2025)
- DBHDS Memo: Updates to Priority Service Categories and Review Timelines (July 2025)
- DBHDS Initial Applicant Orientation, Module 1: Overview of the Process
- DBHDS Initial Applicant Orientation, Module 4: Provider Responsibilities
- Virginia DMAS, Addiction and Recovery Treatment Services (ARTS)
- Virginia DMAS, ARTS Credentialing and Resources for Providers
- Virginia Department of Health, Drug Overdose and Substance Use Data
- Virginia Administrative Code, 12VAC35-105: Rules and Regulations for Licensing Providers by DBHDS