ASAM continued-stay documentation for IOP and PHP reviews

The question a reviewer is answering

The first authorization asks whether this person needs this level of care now. A continued-stay review (also called a concurrent review) asks a narrower question: why does this person still need this level, and what would let them step down? Reviewers read for change. A review that repeats the admission picture, or a note copied forward from last week, reads either as "no progress," which invites a step-down, or as "no need."

Many plans review substance use care against The ASAM Criteria, published by the American Society of Addiction Medicine, and their concurrent review forms (for example Amerigroup Georgia's behavioral health concurrent review form) ask for a short description of each of the six dimensions, along with progress, attendance, risks and the discharge plan. As of its October 2026 edition, the Texas Medicaid behavioral health handbook ties substance use levels of care to the current ASAM Criteria and the HHSC licensing rules. Commercial plans may use ASAM, their own guidelines, or both. Read the medical policy for each plan you bill often, and answer its criteria in its words. One payer's PHP policy, for instance, spells out its own continued-stay documentation (Univera Healthcare, partial hospitalization for SUD).

This page covers the writing. For the authorization process itself (who to call, deadlines, peer-to-peers and appeals) see the prior authorization guide for behavioral health.

Timing: start 5 days before the authorization ends

Most lost days aren't denials. Nobody owned the last authorized day. We start every review 5 calendar days before the last approved day; it's the default in Cima's Program plan for IOP and PHP, and you can set anything from 1 to 14. That leaves time to pull the facts, write, get a clinician's signature, submit, and still have a day for a peer-to-peer if the plan asks for one.

1. 5 days before the last approved dayPull the period's facts: days and hours attended against the schedule, drug screens, PHQ-9 or GAD-7 scores, plan goals worked on, any incidents. Check the plan's own review date: some plans set the review before the last day.
2. 4 days beforeDraft the review from the chart. Every claim in it should point to a note a reviewer could ask for.
3. 3 days beforeThe primary counselor reviews, corrects and signs. The clinical director reads any review asking for a level that the notes don't clearly support.
4. 2 days beforeSubmit by the plan's channel (portal, fax or phone). Write down the reference number, the reviewer's name and the date.
5. 1 day beforeFollow up on anything pending. Be ready for a peer-to-peer with a one-page summary and a clinician who knows the client.

Missed it? Write the review the day you find out and date it that day, with a late-entry note that says why (see how to write a late entry progress note). Never backdate a review or a note. Then ask the plan what it will consider for the uncovered days.

The seven parts of a continued-stay review

Payer forms differ, but they ask for the same few things. A review that has all seven, each specific to this client and this period, covers almost every form we've filled in.

Part	What to write
1. The request	Continue PHP, continue IOP, step down PHP to IOP, step down IOP to OP, or discharge.
2. Days or units, with dates	"8 IOP days, 11/04–11/20, Monday, Wednesday and Friday." Match the schedule and your contract's unit.
3. Progress since the last review	Progress on each treatment plan goal, in measurable terms, with dates. Attendance against the schedule. What changed in the plan and why.
4. Current symptoms, use, cravings and risks	Last use and screen results, cravings with frequency and intensity, screening scores with their trend, safety risk today.
5. The six ASAM dimensions	A rating on the scale the plan's form uses, plus one or two sentences each saying why, and what changed since the last review.
6. Why a lower level can't safely do it	The specific need that the next level down can't meet yet, tied to the dimensions rated highest.
7. Step-down and discharge plan	The step-down criteria, the target date, the next level and provider, and what's already arranged.

The six ASAM dimensions, weak vs. strong

The ASAM Criteria, 4th edition, names the dimensions as below. Some payer forms still use the 3rd edition's names (for example "readiness to change" and "relapse, continued use or continued problem potential"); use the form's words. The examples follow one made-up client, Client A, a 34-year-old in IOP for alcohol use disorder, at the second continued-stay review. A strong entry has a fact, a date or number, a comparison with last time, and what it means for the level of care.

Dimension 1: Intoxication, withdrawal and addiction medications

Current intoxication or withdrawal risk, and any medication for addiction treatment and how it's going.

Dimension 2: Biomedical conditions

Physical health problems that affect treatment or are affected by use.

Dimension 3: Psychiatric and cognitive conditions

Co-occurring mental health conditions, cognition, and safety.

Dimension 4: Substance use-related risks

Cravings, lapses, high-risk situations, and the likely harm if use continues or resumes.

A disclosed lapse with a plan change shows the level of care working. Hiding it, or writing "no use" when a screen says otherwise, is what hurts a review.

Dimension 5: Recovery environment interactions

Housing, relationships, work, school, legal pressures and supports, and how they help or hurt recovery.

Dimension 6: Person-centered considerations

The client's own goals and preferences, motivation, and practical barriers to care.

Every number above has to be in the chart: the PHQ-9s, the attendance (see how to write group therapy notes for IOP so the group days back it up), the lapse in a dated note. If a reviewer asks for the notes, they should say the same thing the review says.

Why a lower level of care can't do it

This is the paragraph reviewers read hardest, and the one most often left generic. Name the specific need, say what the current level does for it that the next level down doesn't, and tie it to the dimensions rated highest. Then say what would change your answer.

The strong version also makes a step-down decision easy for the next review: the criteria are already written, so either they're met or the review says which one isn't and why.

The step-down and discharge plan

A review without a step-down plan reads as open-ended care, and open-ended care is what reviewers cut. Write the step-down plan from the first review, and update it every time.

• Criteria a stranger can check: days without use, a craving frequency, a screening score, attendance, a support in place. Not "when the client is ready."
• A target date, moved when the facts move, with the reason.
• The next level and provider: "OP with her current counselor, 1 session a week," or a named outside therapist, prescriber or support group.
• What's already arranged: the intake appointment, the release of information to send records, the prescriber follow-up, the medication supply until then.
• The discharge plan for after the last level: recovery supports, relapse plan, who to call. The SUD discharge summary guide covers what Texas requires at the end.

If a client steps down early, document that too: a review requesting a step-down is a strong review. It shows the program moves clients when they're ready, which earns trust for the reviews where you ask for more.

A complete sample review

All seven parts for Client A, made up. Real reviews run longer when there's more to say; this is the shape.

What gets days cut

From the reviews we write and the questions reviewers ask us, these are the patterns that lead to fewer days, a step-down, or a peer-to-peer:

• Nothing changed. The same sentences as the last review, or as the admission. Even "no progress" needs to say what was tried and what changes now.
• Ratings with no reasons. "D4: 3" with nothing after it. A reviewer can't check a number.
• The review and the notes disagree. The review says full engagement; the group notes say "minimal participation" three days running.
• Attendance gaps nobody explains. Missed days with no follow-up note, or hours below what the level requires.
• No step-down plan, or one that says "when appropriate."
• Late. Submitted after the last day, which turns a clinical question into an administrative one.

If the plan won't approve the request, ask what it will approve, for how long, and what documentation would change the decision. In Texas, a utilization review agent has to offer the treating provider a chance to discuss the case before it issues an adverse determination (Texas Department of Insurance Bulletin B-0008-19); the peer-to-peer section of the prior authorization guide walks through it.

Texas rules that touch continued stay

For a licensed Texas chemical dependency treatment facility, 26 TAC chapter 564 puts the same ideas into the licensing rules, so the documentation a payer wants is also what an HHSC surveyor reads:

• Plan reviews justify the stay. A treatment plan review must include progress on each goal and objective, revised goals and objectives, and a justification of continued length of stay (26 TAC §564.804(i)). See the SUD treatment plan guide.
• Level changes are documented. A change in intensity, such as PHP to IOP, needs a decision signed by a qualified credentialed counselor (QCC) with the rationale and effective date, a revised treatment plan, and documented coordination with the receiving provider (§564.804(k)).
• Utilization review is part of the program. The rules expect utilization review that checks placement, adequacy of services and length of stay (§564.504).
• Outpatient progress is assessed regularly to set length and intensity (§564.904).

Check the current text with HHSC before you rely on a section number; the rules moved from 25 TAC chapter 448 to 26 TAC chapter 564 in 2024.

How Cima handles UR reviews

Cima EHR for IOP and PHP programs does this work in the app. As built today:

• Authorizations live on the chart, and every one ending in the next 5 days shows on the clinician's Today screen under UR due, marked once a review has been written. Change the 5 to anything from 1 to 14 in settings.
• The continued-stay review has the seven parts above, each required: the request, days or units with dates, progress since the last review, current symptoms and risks, ASAM dimensions 1–6, why the level is still needed ("what a lower level couldn't safely do"), and the step-down and discharge plan. A section that's too short to mean anything (for example, fewer than 20 words of progress) blocks signing with a message saying which one.
• Drafting help, without invented facts. With AI help turned on by the practice owner, type or dictate shorthand and Cima fills in the sections from it; it uses only what you wrote and leaves a section empty rather than guess. You review and sign.
• Step down on the same chart. PHP, IOP and OP are levels on one chart, so the history and the plan move with the client.
• Billing checks the authorization. A per diem day with no authorization covering it is flagged instead of billed.

Want an outside read first? Cima Consulting's chart audit reads ten charts the way a payer auditor or surveyor does, including medical necessity and level-of-care support, with a fix list for each: $750 per 10 charts. Related: group therapy notes for IOP, the SUD treatment plan guide, and Comply's chart audit checklist.

Questions

How often are IOP and PHP continued-stay reviews due?

Each plan sets its own schedule in the authorization: some approve a week or two of PHP at a time and longer stretches of IOP. The review date is on the authorization; ask for it at every approval and write it down. Start the review 5 days before it.

Do I have to rate every ASAM dimension even if it isn't a problem?

Yes, if the plan's form asks for all six, and most do. A low rating with one sentence of why ("no withdrawal signs since admission; screens negative") shows you looked. A blank looks like you didn't.

Should a lapse go in the review?

Yes. Leaving out a lapse the notes or screens show undermines the whole review. A lapse disclosed promptly, with the plan changed in response, is evidence the level of care is working and that the client still needs it.

Which edition of the ASAM Criteria should we use?

Use the one your payer's criteria and forms use. The 4th edition renamed some dimensions, and some plans still use 3rd edition wording. The six dimensions map closely, so write to the form in front of you.

Can a counselor intern write the review?

An intern can draft it, but in Texas level-of-care changes need a QCC's signed decision, and plan reviews by an intern need the supervising QCC's signature. Your payer may also say who must sign. Have a licensed clinician who knows the client review it before it goes out.

What if the plan only approves a step-down?

Ask for the reason and the criteria used, offer a peer-to-peer, and document the conversation. If you disagree, appeal in writing. If the client steps down, update the plan, coordinate with the receiving level, and keep documenting: if things get worse, the notes are your case for stepping back up.

Sources

1. American Society of Addiction Medicine, The ASAM Criteria, 4th edition (dimension names). asam.org
2. Payer concurrent review forms that ask for each ASAM dimension, progress and the discharge plan: Amerigroup Georgia behavioral health concurrent review form; Wellpoint Iowa concurrent review form (inpatient, residential, PHP, IOP). amerigroup.com · wellpoint.com
3. Univera Healthcare, "Partial Hospitalization for Substance Use Disorders" (a payer's continued-stay documentation for PHP). univerahealthcare.com
4. Texas Medicaid Provider Procedures Manual, Behavioral Health Services Handbook, October 2026 (substance use levels of care follow the current ASAM Criteria and HHSC licensing rules). tmhp.com
5. 26 Texas Administrative Code §564.804 (treatment planning, review and level-of-care changes), §564.504 and §564.904. §564.804 · §564.504 · §564.904
6. Texas Insurance Code §4201.206 (opportunity to discuss before an adverse determination); Texas Department of Insurance Bulletin B-0008-19. tdi.texas.gov
7. Cima EHR features described here: the Program plan's continued-stay review, UR due list and per diem checks, as built.

ASAM and The ASAM Criteria are the American Society of Addiction Medicine's; Cima isn't affiliated with or endorsed by ASAM. Payer rules differ by plan and change; confirm with each plan, its medical policies and your contracts.