DHS 75: Summary of changes and FAQ

DHS 75 was created effective August 1, 2000 and replaces the repealed HSS 61.50-61.68. 

Summary of the changes

The following is a summary of the key areas of change addressed in the DHS 75 Community Substance Abuse Services Standards.

  • Purpose for DHS 75.
  • Certifying services rather than programs.
  • Written policy requirements updated to meet changes in state and federal requirements.
  • Requires the application of Uniform Placement Criteria (UPC) in determining a patient’s level of care-placement.
  • Crossover between Intoxicated Driver Program DHS 62 requirements and DHS 75 UPC requirements.
  • Changes in Definitions and General Requirements sections.
  • Knowledge of psychopharmacology and addiction treatment requirement for clinical supervisors.
  • Process for meeting clinical supervision requirements.
  • "Grandfather" provisions of DHS 75.02 (11) (f) and process for certification.
  • Required areas of clinical supervision.
  • Addiction medicine knowledge requirements for medical directors, physicians and service physicians.
  • Process for documenting credentials for medical directors, physicians and clinical supervisors.
  • Changes in assessment and treatment planning requirements.
  • Redefining all levels of services from prevention to treatment-DHS 75.04-75.15.
  • Phasing in of DHS 75 changes in the certification of services.

Frequently Asked Questions

Regarding the use of WI-UPC, clients in treatment for substance abuse have many highs and lows. If a client has been referred to our agency through WI-UPC, does not want to participate, leaves and then returns in a week for treatment, how often should WI-

Unless the client's needs or assets have changed in the interim from the previous application of WI-UPC, and as a result the client?s changed needs or assets would recommend a different level of care, the same level of care previously recommended by WI-UPC can still be utilized. Documentation should be placed in the client record.

Our agency often deals with DOT clients in the Intoxicated Driver Program. DOT requires the use of the WAID assessment. If we use the WAID assessment tool, how does WI-UPC fit in?

WAID is used to determine a client's need for group dynamics or formal treatment services. If treatment services are recommended by the WAID, utilize WI-UPC to determine appropriate level of care for treatment as noted below.

Note: Note: The following represents how the interface between DHS 62 and DHS 75 in regard to the Intoxicated Driver Program (IDP) and the application of Uniform Placement Criteria (UPC) should apply: The IDP Assessor administers the Wisconsin Assessment of the Impaired Driver (WAID) to the court-ordered client and records the WAID findings as one of the following:

Finding of Irresponsible Use: IDP Assessor refers the court-ordered client to the Group Dynamics Program (Assessor does not administer UPC).
Finding of Irresponsible Use-Borderline: IDP Assessor administers the Uniform Placement Criteria to determine the appropriate Driver Safety Plan level of care. **
Finding of Suspected Dependency: IDP Assessor administers the Uniform Placement Criteria to determine the appropriate Driver Safety Plan level of care. **
Finding of Dependency: IDP Assessor administers the Uniform Placement Criteria to determine the appropriate Driver Safety Plan level of care. **
Finding of Dependency in Remission-IDP Assessor administers the Uniform Placement Criteria to determine the appropriate Driver Safety Plan level of care. **
Once a client is referred to a treatment service, UPC is periodically re-administered at the treatment provider's service and results are conveyed back to the IDP Assessor as appropriate.

** For findings of Irresponsible Use-Borderline, Suspected Dependency, Dependency, and Dependency in Remission, the Driver Safety Plan level of care is developed according to the results arrived at in the UPC. 

NOTE: The resulting UPC-identified level of care is to be considered a recommendation. Alternatives to the UPC finding may be used in a driver safety plan and other applications when additional factors, such as client motivation, previous treatment, lack of service availability, and other logistical and clinical judgment factors suggest otherwise.

When a patient enters the emergency room, will the attending physician be responsible to use UPC?

The attending physician must give a medical clearance first. After medical clearance has been given, WI-UPC should be used in order to determine patient placement.

How does the requirement clients from the DOT use the WAID assessment fit with substance abuse treatment?

There is a protocol outlined in the response to question # 2 above that has been developed to provide a linkage from the IDP assessment when the assessment recommends referral to substance abuse treatment. In order for a client to get their driver's license back, they must show progress in meeting the goals in their driver safety plan. If the safety plan includes a recommendation for referral to substance abuse treatment, the WI-UPC would be used to determine the appropriate level of care needed in order for the person to make progress in accomplishing the requirements in their driver safety plan.

What issues regarding clinical supervision need to be addressed in order to qualify for grand-fathering under the provisions of DHS 75.O2 (11) (f)?

The Bureau of Prevention, Treatment and Recovery has developed a process and a checklist of what will be the required documentation and training in order to be certified under the grandfather provision of DHS 75.02 (11) (f) as a certified clinical supervisor. This section of the standards requires 2 years of experience as a clinical supervisor. Applicants for this certification must apply to the Wisconsin Certification Board, Inc. (WCB). The process involves a review of documentation of completion of the applicant's coursework in Psychopharmacology equaling (45) class hours, 15 hours of which shall have been acquired in the last 3 years, and (45) hours in addiction treatment, (15) hours of which shall have been acquired in the last 3 years. A Certified Independent Clinical Social Worker who has documentation of certification and whose employer will attest to the fact that he/she has the documentation that meets the psychopharmacology and addiction treatment requirement is not required to apply under the grandfather provision. A Certified Alcohol and Drug Counselor with two years of experience as a clinical supervisor documented by their agency?s Director contact the WCB to receive a application packet from the WCB. Copies of WCB certification and other documentation should be placed in the agency's personnel file.

Regarding the 45 hours of psychopharmacology training, 15 hours of which must be within the last three years, what if I am not able to verify the training I have obtained?

Documentation will be necessary and can be achieved in the following ways:

Contact the sources from which your training was received, to determine if they may be able to furnish you with documentation of course completion;
Place into your agency staff development plan a goal of taking specific training in the required knowledge areas identified in the clinical supervisor checklist
Have your agency Director verify that you have completed specific training in the areas identified in the clinical supervisor required knowledge checklist
Develop a staff development plan identifying the specific training to be acquired in the knowledge areas of psychopharmacology and/or addiction treatment that are not included in your previous training.

If our agency staff had UPC training about 3 years ago, do we have to send our staff to this training again?

All agency staff who have been previously trained in WI-UPC need not register to take the full training. If you have a number of staff who has previously attended the WI-UPC training, we recommend your agency identify a staff member to retake the training and be designated as your agency WI-UPC "trainer." This individual may then train your agency staff. However, if you have a new employee who has never formally completed WI-UPC training, he/she will need to attend the WI-UPC training and have documentation of certificate of completion in their agency personnel file.

What specific documentation does a Medical Director need?

A medical director must show documentation of having had training in addiction medicine, or include addiction medicine training in their staff development plan. Criteria for knowledge in addiction medicine may be obtained from the American Society of Addiction Medicine (ASAM), the American Board of Psychiatry and Neurology or from the Center for Substance Abuse Treatment (CSAT) Technical Assistance Publication Series # 21(TAP), which describes the Trans-disciplinary Foundations of Addiction Counseling Competencies.

What other placement criteria, other than WI-UPC or ASAM are allowed under DHS 75?

Any placement criteria other than WI-UPC or ASAM must be approved by the DHS, Bureau of Prevention, Treatment and Recovery. The department believes that limiting the number of different types of placement criteria will provide a common language for communication and decision making between the 3rd party payer and the treatment provider should enhance the service authorization process between 3rd party payers and treatment providers.

How backed up are the surveyors on site visits for those agencies who are in need of re-certification?

It is difficult to answer this question since the Bureau of Quality Assurance has one vacant position in the northern region. However the other regions should be handling the certification workload on a monthly basis. Mark Hale, BQA Certification Section Chief has not heard of a backlog due to DHS 75 certification. The Bureau of Quality Assurance is prepared to allow enough time for agencies to comply with DHS 75. If BQA finds that they are running behind, they will look for other expediency measures.

Could you describe the requirement DHS 75.02 (21) Communicable Disease Screening ? AODA Outpatient Services?

Under DHS 75.03 (21) Communicable Disease Screening service staff must conduct a risk assessment for sexually transmitted diseases (STDs), human immunodeficiency virus (HIV), hepatitis B and C or tuberculosis (TB). Further, the Centers for Disease Control and Prevention (CDC) issued its recommendations for prevention and control of Hepatitis C Virus (HCV) Infection and HCV-Related Chronic Disease in the Morbidity and Mortality Weekly Report dated October 16, 1998, Vol. 47, No. RR-19.

All AODA outpatient treatment services must conduct an assessment (oral interview) of risk factors for communicable diseases on all clients upon admission and at least once a year. If the individual has been evaluated for factors within the previous six months, it is not necessary for the AODA outpatient treatment service to conduct a new evaluation, unless the client exhibits symptoms. Staff members must be screened yearly/annually for tuberculosis (TB). All AODA programs were notified regarding requirements for screening for tuberculosis (TB). The information identified in Memo Series DSL-99-06/Action dated April 22, 1999 is to continue to be used.

Last Revised: July 13, 2016