In California, people are being denied medically necessary detox care not because it isn’t needed, but because the state refuses to clearly name the level of care being provided.

ASAM Level 3.7—Medically Monitored Intensive Inpatient Services—is not ambiguous. It requires 24/7 onsite LVN or LPT nursing coverage with RN oversight, whether that oversight is provided through direct employment or a contracted arrangement. When this nursing model is in place, and when Incidental Medical Services (IMS) are being delivered, programs are operating at the ASAM 3.7 level of care.

Yet in California, ASAM 3.7 effectively does not exist.

For more than thirty years, the addiction treatment field has relied on the ASAM Criteria to make risk-based placement decisions. From the earliest Patient Placement Criteria through the current Fourth Edition, the purpose has always been the same: to give clinicians, systems, and payers a shared language so people are placed in the right level of care at the right time.

That shared language breaks down in California the moment detox is involved.

Under current Department of Health Care Services (DHCS) policy and level-of-care designation, residential detox services are collapsed into “clinically managed” withdrawal management, regardless of the actual medical intensity required by the patient. Programs that operate with round-the-clock nursing, RN oversight, and IMS are still forced to seek authorization under a lower-intensity label.

The result is predictable—and deeply harmful.

Most insurers and utilization management systems recognize ASAM 3.7 as the standard for residential, medically monitored detox. Their authorization frameworks are built around that understanding. When California providers are required to describe 3.7-level care as something else, denials follow—not because the care isn’t medically necessary, but because the terminology doesn’t match the risk.

These denials do not occur in low-stakes situations. They occur at the most dangerous moment in treatment—when people are withdrawing from alcohol, benzodiazepines, or opioids; when seizure risk is real; when confusion, delirium, and medical instability are present. Detox is not elective. It is time-sensitive and risk-driven.

Incidental Medical Services exist for a reason. They were created because certain residential populations cannot be safely treated without on-site medical care. Many residential programs in California are already doing exactly what ASAM 3.7 describes: managing complex withdrawal presentations with continuous nursing, clear RN oversight, and defined medical protocols. Clinically, the work is happening. Administratively, the state refuses to call it what it is.

This is not a disagreement about clinical standards. It is a policy failure.

California law requires DHCS to adopt ASAM or equivalent criteria as the minimum standard of care. DHCS has invested heavily in ASAM-based assessment tools and compliance frameworks. But without explicitly recognizing ASAM 3.7, the state undermines its own system and forces providers and patients into an avoidable gray zone.

The fix is straightforward.

DHCS must explicitly recognize ASAM 3.7 as residential, medically monitored withdrawal management. It must clearly cross-walk residential detox programs operating with IMS and appropriate nursing models to ASAM 3.7. And it must require payers and counties to honor that alignment in authorization decisions.

This is not about expanding services or increasing costs. It is about accurately naming care that already exists so people are not denied treatment over paperwork.

When the state refuses to recognize ASAM 3.7, it does not eliminate residential detox. It simply shifts risk—from systems to providers, and ultimately, to patients.

California can do better. The standards are already written. The care is already being delivered. What’s missing is the will to align policy with reality.

And when it comes to detox, that alignment can be the difference between stabilization and catastrophe.

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Pete Nielsen President & CEO
Pete Nielsen is the President & Chief Executive Officer for the California Consortium of Addiction Programs and Professionals (CCAPP), CCAPP Credentialing, CCAPP Education Institute, and the National Behavioral Health Association of Providers (NBHAP). CCAPP is the largest statewide consortium of addiction programs and professionals, and the only one representing all modalities of substance use disorder treatment programs. NBHAP is the leading and unifying voice of addiction-focused treatment programs nationally. Mr. Nielsen has worked in the substance use disorders field for 20 years. In addition to association management, he brings to the table experience as an interventionist, family recovery specialist, counselor, administrator, and educator, with positions including campus director, academic dean, and instructor. Mr. Nielsen is the secretary of the International Certification and Reciprocity Consortium and the publisher for Counselor magazine. He is a nationally known speaker and writer published in numerous industry-specific magazines.  Mr. Nielsen holds a Master of Science in Counseling Psychology and a Bachelor of Science in Business Management.