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January 7, 2026 Marlin Martin, Authorized Agent Valhalla Place Brainerd LLC 5001 Spring Valley Road STE 600E Dallas, TX 75244-8217 License Number: 1108974 (245G) CORRECTION ORDER Dear Marlin Martin, On November 5, 6 and 7, 2025 Department of Human Services (DHS) licensor conducted a licensing review at your facility, Valhalla Place Brainerd LLC dba BHG Brainerd Treatment Center located at 2215 S 6th Street, Brainerd MN 56401. This review was conducted to determine compliance with state and federal laws and rules governing the provision of substance use disorder treatment under Minnesota Statute, chapter 245G. As a result, DHS is issuing this order which requires you to take the correction action as described under each violation. Details of our findings are provided below. Our next steps and your options are also detailed. LICENSING VIOLATIONS DHS determined that your program failed to follow licensing rules and statutes, as described below. Policy, Procedures and Practices 1. Violation: The license holder did not meet requirements governing service initiation policy. The service initiation policy did not contain service initiation preferences that comply with the Code of Federal Regulations, title 45, part 96.131. Statute Violated: Minnesota Statutes, section 245G.14 subdivision 1. Corrective Action Required: Immediately and on an ongoing basis the license holder must ensure that the service initiation policy meets all applicable requirements. Within 30 days of receipt of this order the license holder will submit an updated services initiation policy that meets all applicable requirements. 2. Violation: The license holder’s policies and procedures reviewed for requirements governing the provision of telehealth in accordance with Minnesota Statutes, sections 254B.05, subdivision 5, paragraph (f) and 256B.0625, subdivision 3b did not meet requirements. The telehealth policies and procedures did not: a. Adequately address patient safety before, during and after the service is delivered through telehealth; b. Establish protocols addressing how and when to discontinue telehealth services; and c. Establish quality assurances process related to delivering services through telehealth. Statute Violated: Minnesota Statutes, section 245G.07, subdivision 4, paragraph (c), clause (2). Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that the telehealth policies and procedures meet all applicable requirements. Within 30 days of receipt of this order, submit an updated telehealth policy that meets all appliable statute requirements. Client Files 3. Violation: Two of four client files reviewed for client record documentation did not meet requirements in the following ways: a. Treatment service documentation was not completed within 7 days for a service that was provided on May 27, 2025 (client file numbered 4); b. Services provided via telehealth did not contain the following: i. Determination that telehealth is an appropriate and effective means for delivering the treatment service on the following dates: 1. October 29, 2025, and November 5, 2025 (client file numbered 2); and 2. August 12, 2025, September 3, 2025, October 2 and 21, 2025 and November 4, 2025 (client file numbered 4); and ii. Mode of transmission used to deliver the service through telehealth on the following dates: 1. October 29, 2025, and November 5, 2025 (client file numbered 2); and 2. August 12, 2025, September 3, 2025, October 2 and 21, 2025 and November 4, 2025 (client file numbered 4); and iii. The location of the originating site and the distance site on the following dates: 1. October 29, 2025, and November 5, 2025 (client file numbered 2); and 2. August 12, 2025, September 3, 2025, October 2 and 21, 2025 and November 4, 2025 (client file numbered 4). Statute Violated: Minnesota Statutes, sections 245G.06, subdivision 2a and 245G.07 subdivision 4, paragraph (c), clause 2. Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure requirements governing client record documentation are met. 4. Violation: One of three client files reviewed for requirements governing treatment plan reviews did not meet requirements (client file numbered 1). Treatment plan reviews were not completed weekly for the ten weeks following completion of the treatment plan. There was no documentation of a treatment plan review for the weeks beginning September 1, 2025, and October 6, 2025. Statute Violated: Minnesota Statutes, section 245G.06, subdivision 3a, paragraph (f). Repeat Violation: The license holder was previously found in violation of the same statute in orders dated July 8, 2025, December 17, 2024, and October 2, 2023. 5. Violation: Two of two client files reviewed for requirements governing the criteria for unsupervised use of methadone hydrochloride did not meet requirements. There was no documentation that a practitioner reviewed the criteria in the Code of Federal Regulations, title 42, part 8.12 (i) (2) when determining whether dispending medication for a client’s unsupervised use is safe and appropriate to implement or increase on the following dates: a. October 30, 2025 (client file numbered 3); and b. April 22, 2025 (client file numbered 4). Statute Violated: Minnesota Statutes, sections 245G.22, subdivision 6, paragraphs (b) and (c). Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure requirements governing criteria for unsupervised use of methadone hydrochloride are met. Written Response Required If you fail to correct the violation(s) specified in the Correction Order within the prescribed time lines the Commissioner may issue an Order of Conditional License or may impose a fine and order other licensing sanctions pursuant to Minnesota Statutes, sections 245A.06 and 245A.07. Submissions required as part of the corrective action ordered must be sent to your licensor by email at jennifer.eppel@state.mn.us or by mail: Commissioner, Department of Human Services ATTN: Jennifer Eppel Licensing Division PO Box 64242 St. Paul, MN 55164-0242 YOUR RIGHT TO REQUEST RECONSIDERATION You have the right to request reconsideration of this order and the cited violations. Your request must: · Be in writing · List each violation you are challenging and identify what is inaccurate or incomplete about the information in the order · Supply information that is accurate or more complete · Be made before the deadlines provided below If you are mailing your request, it must be received by DHS within 20 calendar days from when you received this order. If you do not meet this deadline, you lose your right to request reconsideration. The timeline to appeal began when you received this order. Please send it to: Office of Inspector General Legal Counsel’s Office Attn: 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 - Licensing 444 Lafayette Road North St. Paul, MN 55155 Legal authority This action is taken under Minnesota Statutes, section 245A.06, subdivision 1. The timeline to request reconsideration of the order is provided in Minnesota Statutes, section 245A.06, subdivision 2. Questions If you have any further questions regarding this matter, you may contact me at 651-431-6698 or at jennifer.eppel@state.mn.us Sincerely, Jennifer Eppel, Licensor Licensing Division Office of Inspector General
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