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July 22, 2025 CERTIFIED MAIL Yusuf Mohamed, Authorized Agent Transform Lives LLC 1250 E Moore Lake Drive, Suite 150 Fridley, MN 55432
License Application Number 1124591 (245G)
AMENDED ORDER OF LICENSE DENIAL
NOTICE: This Amended Order of License Denial supersedes an Order of License Denial issued on July 7, 2025, which must be destroyed. The Department of Human Services, Division of Licensing (DHS) updated the mailing address of the Order of License Denial issued on July 7, 2025. This Amended Order reflects the correct mailing address. Dear Yusuf Mohamed: The Department of Human Services (DHS) is denying your application for a substance use disorder (SUD) treatment program license at 1250 E Moore Lake Drive, Suite 150, Fridley, MN 55432. This denial is based on not being able to demonstrate competent knowledge of applicable licensing statutes and rules and not submitting a substantially complete application. Details of our findings are provided below. Our next steps and your options are also detailed. REASON FOR LICENSE DENIAL
1. Did not submit a substantially complete application
You submitted an application for a license to provide substance use disorder treatment services at 1250 E Moore Lake Drive, Suite 150, Fridley, MN 55432. A DHS licensor reviewed your full policy and procedure manual and determined that the manual was substantially incomplete. On January 31, 2025, a video call with a DHS Licensor was conducted informing you of specific information on what was missing and/or out of compliance after completing a review of the required elements of an application. This information was also provided to you in writing in the Notice of Incomplete Application, along with a detailed checklist outlining areas of noncompliance. On February 12, 2025, DHS sent you a Notice of Incomplete Application, notifying you that your application was incomplete and that you had 45 days to submit additional information. You signed the certified mail on February 28, 2025. DHS Licensing received your revised policy and procedure manual on March 17, 2025. After a review was conducted, your licensor met with you on May 9, 2025, to provide you with feedback on continued areas of non-compliance. Upon further review, DHS determined your application continued to be substantially incomplete in the following ways: · You did not provide a qualified Treatment Director as required under Minnesota Statutes, section 245G.10, subdivision 1. DHS determined the individual you identified as your program’s Treatment Director did not meet the required qualifications.
· You did not submit a policy and procedure manual that met all applicable requirements. Based upon review, the following policies were not in compliance with 245G requirements:
o The policy manual contained policies that referenced medical services that you confirmed will not be provided. The policies and procedures initially submitted with your application references medical services provided by health care providers. During a video call on January 31, 2025, you confirmed there would not be medical services provided by health care providers and were provided feedback to remove references to these services. The revised policy and procedure manual that you submitted on March 17, 2025, continued to include medical references in the following policies:
§ Service initiation
§ Treatment service description
§ Medical services
§ Job descriptions
§ Organizational chart
o Comprehensive assessment policy: includes conflicting information and references repealed Minnesota Statute language.
o Treatment planning policy: includes conflicting information regarding timelines for completion and references to repealed Minnesota Statute language.
o Service initiation: missing requirements for a denial of service initiation that involves the commission of a crime.
o Service termination: missing requirements for procedures that staff members must follow when a client admitted under Minnesota Statutes, chapter 254B is to have services terminated.
o Client rights: did not reference Minnesota Statutes, section 253B.03.
o Grievance procedure: missing the current addresses and phone numbers of required reporting agencies.
o Personal electronic device policy: includes conflicting information on the use of personal electronic devices.
o Treatment service description: missing requirements for amounts of treatment services offered and guest speakers.
o Co-occurring disorder policy: missing requirements for the program to have continuing access to a medical provider with appropriate expertise in prescribing psychotropic medication and a mental health professional available for staff member supervision and consultation.
o HIV minimum standards policy: inconsistent with HIV minimum standards according to Minnesota Statutes, section 245A.19.
o Program abuse prevention plan: includes references to providing services to adolescents (applicant did not apply to serve adolescents) and repealed Minnesota Statute language.
o Vulnerable adults reporting: includes conflicting information regarding Minnesota Statute definitions of maltreatment.
o Maltreatment of minors reporting: includes incorrect references to Minnesota Statutes.
o Plan for transfer of client records upon closure: missing signed agreement or other documentation indicating that a county or similarly licensed provider has agreed to accept and maintain the program’s closed case records.
o Personnel Policies:
§ Job descriptions were inconsistent with organizational chart.
§ Job descriptions were missing qualification requirements.
You were informed of this, along with the specific information on what was missing and/or out of compliance through a video call with a DHS Licensor on January 31, 2025. This information was also provided to you in writing in the Notice of Incomplete Application, along with a detailed checklist outlining areas of noncompliance, which was delivered via certified mail on February 28, 2025. This notice required that a substantially complete application be submitted to DHS licensing within 45 days. Legal Authority: 245A.05, subdivision (a)(1). 2. Did not demonstrate competent knowledge of applicable licensing statutes and rules
Based on communications with you during the license application process, DHS determined that you were unable to demonstrate an ability to operate a substance use disorder treatment program in compliance with Minnesota statutes and rules. During the May 9, 2025, video meeting, the applicant asked if a Treatment Director was needed, or if a program can just have an Alcohol and Drug Counselor. This demonstrated lack of knowledge with Minnesota Statutes, chapter 245G requirements. Without this knowledge, you are unable to ensure the safety and well-being of vulnerable adults who would be served by the program. You were not able to submit a substantially complete application after receiving assistance from DHS. The DHS website where you found the online application provides the application process and hyperlinks to the Minnesota statutes applicable to substance use disorder treatment programs. A DHS licensor also provided you with a policies and procedures checklist that identified applicable statute requirements and written feedback on the policies and procedures manual you submitted with your application. Despite these resources, you submitted policies and procedures that did not meet statute requirements. Legal Authority: Minnesota Statutes, sections 245A.04, subdivision 6(a)(5); and 245A.05, subdivision (a)(8). 3. Commissioner’s evaluation of program
Before issuing, denying, suspending, revoking, or making conditional a license, the commissioner shall evaluate information gathered under Minnesota Statutes, section 245A.04, subdivision 6. The commissioner’s evaluation shall consider the applicable requirements of statutes and rules for the program or services for which the applicant seeks a license including, disqualification standards set forth in chapter 245C. The commissioner shall evaluate facts, conditions, or circumstances concerning the programs operation; the well-being of persons served; available evaluations of the program by persons receiving services; the qualifications of personnel employed by the applicant; and applicant’s ability to demonstrate competent knowledge of applicable statutes and rules. Your inability to submit a complete application in 45 days after receiving assistance from DHS calls into question your ability to follow the applicable laws and rules; to be able to operate a program; and to ensure the well-being of persons served. You also did not provide qualified personnel for the Treatment Director position. A Treatment Director that meets the requirements of Minnesota Statutes, section 245G.10, subdivision 1 is required for all licensed SUD programs. This position provides management and oversight of the program and is responsible for the delivery of treatment services. You did not identify a qualified individual for this position, which indicates that you are either unable or unwilling to comply with the licensing requirements. As a result, DHS is concerned about your ability to provide for the health and safety of vulnerable persons you seek to serve. DHS has determined that the denial of your license is appropriate based on the violations identified above and the program evaluation. Legal Authority: Minnesota Statutes, section 245A.04, subdivision 6. YOUR RIGHT TO APPEAL
You have the right to appeal the denial. Your request must be in writing and clearly state that you are requesting a contested case hearing for this matter. Your request must be made before the deadlines provided below. If you do not meet this deadline, you lose your right to an administrative appeal. The timeline to appeal began when you received this order. If you are mailing your request, it must be sent by certified mail and postmarked within 20 calendar days from when you received this order. Please send it to: Commissioner, Department of Human Services Office of Inspector General Legal Counsel’s Office Attention: Licensing Legal Unit PO Box 64953 St. Paul, MN 55164-0953 If your request is being personally delivered, it must be received by DHS within 20 calendar days from when you received this order. Please bring it to: Commissioner, Department of Human Services Office of Inspector General Legal Counsel’s Office Attention: Licensing Legal Unit 444 Lafayette Road North St. Paul, MN 55155 Upon DHS’ receipt of your timely appeal, your case would be scheduled for a contested case hearing in front of an Administrative Law Judge. Following this hearing, the Commissioner of DHS will issue a final order. If you do not appeal or if the order is affirmed by the Commissioner following a hearing, DHS is prohibited from issuing you and the controlling individuals a license for two years. Legal representation at the contested case hearing:
You do not need a lawyer to appeal. However, a lawyer can help you with your appeal. The state or county will not get you a lawyer and will not pay for a lawyer. If you cannot afford a lawyer, you may be able to get free legal advice or help with your appeal. To find out if free help is available, contact: Volunteer Lawyers Network at 612-752-6677; Central Minnesota Legal Services at 612-332-8151; Southern Minnesota Legal Services at 651-222-4731; or go to www.lawhelpmn.org to find a local legal services program that may be able to help you. You can also find information on contested cases from the Office of Administrative Hearings website at https://mn.gov/oah/self-help. Click on Administrative Law Overview, then click on Administrative Law Contested Case Hearing Guide for a list of frequently asked questions. Legal authority for this licensing action
· This action is taken under Minnesota Statutes, section 245A.05, subdivision (a), which describes under which conditions DHS may deny an application.
· “Controlling individual” is defined under Minnesota Statutes, section 245A.02, subdivision 5a.
· License holders have a right to appeal licensing actions and request a contested case hearing, under Minnesota Statutes, chapter 14 and Minnesota Rules, parts 1400.8505 to 1400.8612.
· Under Minnesota Statutes, section 245A.04, subdivision 7, paragraph (d), clause (2), the commissioner shall not issue or reissue a license if the applicant, license holder, or controlling individual has been denied a license under this chapter within the past two years.
Questions
If you have any further questions regarding this matter, you may contact Maura McGarry, Supervisor, at 651-431-6671. Sincerely, 
Paula Halverson, Unit Manager Licensing Division Office of Inspector General
PO Box 64242 • Saint Paul, Minnesota • 55164-0242 • An Equal Opportunity and Veteran Friendly Employer https://mn.gov/dhs/general-public/licensing/
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