Many drug and alcohol treatment facilities see continuity of care and income opportunities in providing qualitative (and even quantitative) toxicology screening to make sure they know (1) what their residents/patients are taking, and (2) in what quantities. Facilities need to make sure they know that federal and state law will view them as a clinical lab, even when they are simply taking urine and using cups. CLIA will require they obtain “waived” status (since dipsticks are in that category). Facilities also need to examine whether state licensure (as a “Healthcare Clinic”) is also required. Chapter 400, Florida Statutes requires any entity to obtain a healthcare clinic license if (a) healthcare services are provided, and (b) claims for those services are submitted. Even though most facilities are out of network, most do submit claims to insurance carriers and hence implicate the state healthcare clinic license law (which is different from the CLIA law).
