On National HIV Testing Day, SAMHSA Encourages Everyone at Risk for HIV to Get Tested
Impact on your practice
This is a public health awareness campaign with minimal direct impact on therapy practice operations, billing, or licensure. Relevant only if your practice screens for or refers on HIV testing.
Key facts
SAMHSA promoting routine HIV testing for ages 13-64
Testing framed as self-care and preventive health
CDC recommends at least one lifetime test for all adults
Therapy Companion analysis
This SAMHSA guidance creates a compliance expectation for therapists receiving federal grant funding, particularly those in substance use treatment or integrated behavioral health settings. If your practice receives SAMHSA grants, you should understand that HIV testing integration is now positioned as a routine clinical requirement, not an optional service enhancement. For solo practitioners and small agencies without grant funding, this remains advisory rather than mandatory, but the trend signals that payers and accreditors will increasingly expect HIV screening protocols. The practical impact depends on your funding model: SAMHSA grant recipients must document HIV testing procedures, ensure staff complete CME training on HIV screening, and maintain inventory of self-testing kits for distribution. This creates documentation burden—you'll need to track which clients were offered testing, their risk stratification (CDC recommends annual testing for those with risk factors), and referral pathways for positive results. For therapists in private practice without grants, the guidance reinforces that routine HIV screening during intake or risk assessment conversations is now standard of care, particularly when treating clients with substance use disorders or mental illness. The financial impact is minimal if you're already screening; the cost is primarily staff time for training and kit procurement. However, if your practice has avoided HIV screening, implementing it now positions you ahead of likely future insurance or licensing board expectations around integrated preventive health screening.
Background
SAMHSA issued this guidance during the COVID-19 pandemic when mental health and substance use treatment demand surged, yet HIV testing rates stalled due to clinic closures and reduced in-person services. The broader context is that people with serious mental illness and substance use disorders experience HIV infection rates 2-3 times higher than the general population, yet remain undertested and undertreated. CDC guidelines have recommended universal HIV testing for all adults 13-64 since 2006, but adoption in behavioral health settings remains inconsistent. SAMHSA's emphasis on self-testing kits and flexible testing modalities reflects recognition that traditional clinic-based testing creates barriers for vulnerable populations. By framing HIV testing as 'self-care' and a mental health issue (not just an infectious disease issue), SAMHSA is signaling that behavioral health providers have a responsibility to normalize testing and remove stigma. This aligns with the federal 'Ending the HIV Epidemic' initiative launched in 2019, which targets specific geographic areas and populations for intensive testing and treatment. For therapists, this represents a shift in how federal agencies view your role: you're now expected to be a point of entry for preventive health screening, not just mental health treatment.
What you should do
If your practice receives any SAMHSA funding (SAMHSA-HRSA grants, SBIRT funding, opioid treatment program grants, etc.), audit your current HIV testing protocols immediately. Document whether you have written screening procedures, staff training records, and self-testing kit inventory. If gaps exist, develop a compliance plan with timelines for staff CME training and kit procurement before your next grant reporting period.
Integrate HIV risk assessment into your standard intake or clinical assessment form, particularly for clients with substance use disorder, mental illness, or both. Use CDC risk stratification language (lifetime testing for all; annual testing for those with risk factors) to guide your screening conversations and documentation.
Establish a referral pathway for clients who test positive or request testing. Know which local testing sites accept your insurance, which offer same-day results, and which provide linkage to care services. Include this information in your client materials and staff training.
If you employ clinical staff (LCSWs, LPCs, MFTs, psychiatric NPs), require completion of CDC-approved HIV screening CME training within 90 days. Document completion in personnel files. This protects your practice from liability and ensures consistent, evidence-based screening.
Review your electronic health record (EHR) to ensure you can document HIV testing offers, client responses, results (if applicable), and referrals. If your EHR lacks these fields, request an update or create a supplemental tracking mechanism to maintain compliance documentation.
Notable excerpts
"Everyone between the ages of 13 and 64 should get tested for HIV at least once per lifetime as part of routine health care. Those with certain risk factors may benefit from testing at least once a year, or once every 3-6 months, depending on risk." – CDC guidance cited by SAMHSA
"SAMHSA has long encouraged substance use disorder and mental health treatment providers to integrate HIV testing into routine care. In fact, it is a requirement for some of SAMHSA's grants." – SAMHSA statement on grant compliance expectations
"People with mental illness and/or substance use disorder are at increased risk of getting and transmitting HIV." – SAMHSA, identifying behavioral health populations as priority for testing
View full source text
Policy changes drive denial patterns
Therapy Companion tracks both: the policy shifts on this page and the denial patterns hitting your claims.
Related policy changes
[MA] H4895: Expanding access to mental health services
This bill aims to expand mental health service access in Massachusetts and has cleared committee with a favorable recommendation. Depending on final language, it could affect reimbursement rates, telehealth authorization, or insurance coverage requirements.
[TN] SB1248: AN ACT to amend Tennessee Code Annotated, Title 4; Title 8; Title 33; Title 39; Title 49; Title 53; Title 56; Title 63; Title 68 and Title 71, relative to mental health.
This comprehensive TN mental health bill touches multiple code sections and could affect licensure, scope of practice, insurance requirements, and workforce regulations. Therapists should monitor its progress closely as it moves through committee.
Advancing the Future of Behavioral Health Data Exchange
This policy direction addresses a critical pain point for therapists: the lack of integrated health data exchange with primary care and medical providers. Improved interoperability could reduce documentation burden, improve care coordination, and reduce liability from medication interactions or missed diagnoses. However, it may also increase compliance requirements and data security obligations.
Opinion: MAHA is rewriting the vocabulary of American mental health care
Federal deprescribing initiatives create new clinical and billing opportunities for therapists while potentially pressuring prescribing practices. Therapists should understand the evidence, reimbursement rules, and ethical considerations around medication tapering to protect clients and navigate changing clinical norms.