Minnesota

April 9, 2026

Ryan Thorson, Authorized Agent

Independent Management Services

101 21st St SE

Austin, MN 55912

License Number: 1108133

License Number: 1101046

CORRECTION ORDER

Dear Ryan:

On February 9 through 11, a 2026 Department of Human Services (DHS) licensor conducted a licensing review at your facility, Independent Management Services, located at:

· 101 21st St SE, Austin, MN 55912, license number 1108133

· 709 Algon St, Albert Lea, MN 56007, license number 1101046

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.

Policies, Procedures, and Practices

1. Violation: The license holder did not meet requirements governing client rights protections (license number 1108133 and 1101046). The policy and procedure manual did not contain policies and procedures that protect client rights as identified in Minnesota Statues, section 144.651.

Statute Violated: Minnesota statutes, section 245G.15, subdivision 1.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that client rights policy and procedure meet all applicable requirements. Within 30 days of receipt of this order, submit a client rights policy that demonstrates compliance.

2. Violation: The license holder did not meet requirements governing grievance procedures (license number 1108133 and 1101046) in the following ways:

a. The grievance procedure did not contain the current address for The Minnesota Board of Behavioral Health and Therapy; and

b. The grievance procedure did not include a statement that the client may bring the grievance to the highest level of authority in the program if not resolved by another staff member.

Statute Violated: Minnesota statutes, section 245G.15, subdivision 2, clause (2) and (3).

3. Violation: The license holder did not meet requirements governing treatment services (license number 1108133 and 1101046). The treatment services description did not include the amount and type of services provided.

Statute Violated: Minnesota statutes, section 245G.12, clause 10.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that the treatment services description meet all applicable requirements. Within 30 days of receipt of this order, submit a description of treatment services that demonstrates compliance.

4. Violation: The license holder did not meet requirements governing telehealth services (license number 1108133 and 1101046) according to Minnesota Statute 256B.0625, subdivision 3b, paragraph (c). The license holder’s treatment services description did not identify the categories or types of service the health care provider will provide through telehealth.

Statute Violated: Minnesota statutes, section 245G.07, subdivision 4.

5. Violation: The license holder did not meet requirements governing health services (license number 1108133 and 1101046). The policies and procedures were not consistent with HIV minimum standards.

Statute Violated: Minnesota statutes, section 245A.19, paragraph (d).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that health services meet all applicable requirements. Within 30 days of receipt of this order, submit an HIV policy that demonstrates compliance.

6. Violation: The license holder did not meet requirements for monitoring implementation of program policies and procedures necessary to maintain compliance with licensing requirements. The license holder’s maltreatment of vulnerable adults report policy included outdated statute definitions.

Statute Violated: Minnesota statutes, section 245A.04, subdivision 14, paragraph (b), clause (3).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that vulnerable adult maltreatment reporting policy and procedures meet all applicable requirements. Within 30 days of receipt of this order, submit a maltreatment of vulnerable adults reporting policy that demonstrates compliance.

Personnel Files

· License number 1108133: Personnel files 1 through 3

· License number 1101046: Personnel files 4 through 5

7. Violation: Two of two personnel files reviewed for requirements governing staff orientation did not meet requirements. Personnel files did not contain documentation of orientation to:

a. Client needs within 24 working hours (personnel files numbered 1 and 4);

b. Maltreatment of Minors before the mandatory reporter has direct contact (personnel files numbered 1 and 4); and

c. Emergency overdose training before direct contact (personnel file numbered 4).

Statute Violated: Minnesota statutes, section 245G.13, subdivisions 1, clause (7) and 2, paragraph (e); section 245G.08, subdivision 3; and section 245A.242, subdivision 2, paragraph (a).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that staff orientation meets all applicable requirements.

8. Violation: Four of four personnel files reviewed for requirements governing annual training did not meet requirements. The personnel files did not contain documentation of the following annual trainings:

a. For calendar year 2024:

1) Mandatory reporting as specified in Minnesota Statutes, sections 245A.65, 626.557, 626.5572, and chapter 260E (personnel file numbered 3);

2) License holder’s policies for obtaining a release of client information (personnel files numbered 2, 3, and 5);

3) License holder’s program abuse prevention plan (personnel file numbered 3);

4) All internal policies and procedures related to the prevention and reporting of maltreatment of individuals receiving services (personnel file numbered 2, 3 and 5);

5) Reporting of maltreatment of minors (personnel file numbered 3);

6) HIV minimum standards (personnel file numbered 3); and

7) License holder’s policies and procedures for working with HIV-infected clients and referring clients to individual HIV counseling and services when needed (personnel file numbered 2, 3, and 5).

b. For calendar year 2025:

1) Mandatory reporting as specified in Minnesota Statutes, sections 245A.65, 626.557, 626.5572, and chapter 260E (personnel files numbered 1 and 3);

2) License holder’s policies for obtaining a release of client information (personnel files numbered 1, 2, 3, and 5);

3) License holder’s program abuse prevention plan (personnel files numbered 1 and 3);

4) All internal policies and procedures related to the prevention and reporting of maltreatment of individuals receiving services (personnel file numbered 1, 2, 3 and 5);

5) Reporting of maltreatment of minors (personnel files numbered 1 and 3);

6) HIV minimum standards (personnel files numbered 1 and 3);

7) License holder’s policies and procedures for working with HIV-infected clients and referring clients to individual HIV counseling and services when needed (personnel file numbered 1, 2, 3, and 5);

Statute Violated: Minnesota statutes, sections 245G.13, subdivision 2, paragraphs (c), (d), and (e), and 245A.65, subdivision 3.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that annual training meets all applicable requirements.

9. Violation: Three of three personnel files reviewed for requirements governing every two-year training did not meet requirements. The personnel files did not contain documentation of the following every two-year trainings for calendar year 2025:

1) Emergency procedures (personnel file numbered 3); and

2) Client rights as specified in 144.651, 148F.165, and 253B.03 (personnel files numbered 2, 3, and 5).

Statute Violated: Minnesota statutes, sections 245G.13, subdivision 2, paragraphs (b), clause (2)

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that annual training meets all applicable requirements.

10. Violation: Two of four personnel files reviewed for requirements governing personnel file contents did not meet requirements. Personnel files did not contain the following:

a. A completed application for employment signed by the staff member (personnel files numbered 1 and 2); and

b. Documentation of an inquiry required by sections 604.20 to 604.205 made to the staff member’s former employers regarding substantiated sexual contact with a client (personnel file numbered 1).

Statute Violated: Minnesota statutes, section 245G.13, subdivision 3, clause (1) and (3).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that personnel files meet all applicable requirements.

Client Files

· License number 1108133: Client files 1 through 3

· License number 1101046: Client files 4 through 5

11. Violation: Four of four client files reviewed for requirements governing initial services plan (ISP) did not meet requirements in the following ways:

a. The ISP was not completed within 24 hours of the day of service initiation (client files numbered 1 and 2); and

b. The ISP was not client-specific (client files numbered 4 and 5).

Statute Violated: Minnesota statutes, section 245G.04, subdivision 1.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that initial service plan meet all applicable requirements.

12. Violation: Two of four client files reviewed for requirements governing vulnerable adult assessment and determination (client files numbered 1 and 2) did not meet requirements. A vulnerable adult assessment and determination was not completed within 24 hours of the day of service initiation.

Statute Violated: Minnesota statutes, section 245G.04, subdivision 2.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that Vulnerable Adult Assessment and Determination meet all applicable requirements.

13. Violation: Two of four client files reviewed for requirements governing Comprehensive Assessments (CA) did not meet requirements. The CA did not contain the following:

a. The client’s household members (client file numbered 2);

b. The client’s evaluation of the quality of each personal relationship (client file numbered 5); and

c. The client’s family health history (client file numbered 5).

Statute Violated: Minnesota statutes, section 245G.05, subdivision 3.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that comprehensive assessments meet all applicable requirements.

14. Violation: Four of four client files reviewed for requirements governing Individual treatment plans (ITP) did not meet requirements in the following ways:

a. The ITP was not completed by the end of the tenth day on which a treatment service has been provided from the day of service initiation (client file numbered 1); and

b. The ITP did not contain a treatment strategy (client files numbered 2, 4, and 5).

Statute Violated: Minnesota statutes, section 245G.06, subdivisions 1 and 1a, paragraph (a), clause (3).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that individual treatment plans meet all applicable requirements. Within 30 days of receipt of this order, submit an individual treatment plan that demonstrates compliance.

15. Violation: Five of five client files reviewed for requirements governing documentation of treatment services did not meet requirements as follows:

a. The client file did not contain documentation of the following:

1) Amount of each treatment service provided to a client on:

(i) January 20, 22, 26 and 27, 2026 (client file numbered 1);

(ii) October 13, 14, 16, 20, 21, 23, and 27, 2025 (client file numbered 2);

(iii) January 19, 2026 (client file numbered 3);

(iv) January 22, 26, 27, 29 and, February 2, and 3, 2026 (client file numbered 4); and

(v) July 15, 17, 21, 22, 24, and 28, 2025 (client file numbered 5); and

2) Type of each treatment service provided to a client on:

(i) January 27, 2026 (client file numbered 1);

(ii) October 14, 20, and 27, 2025 (client file numbered 2);

(iii) January 19, 2026 (client file numbered 3);

(iv) February 3, 2026 (client file numbered 4); and

(v) July 21, 22, and 24, 2025 (client file numbered 5); and

b. Documentation was not signed by the staff member who provided the treatment service on July 22, 2025 (client file numbered 5); and

c. The job title or position of the staff that made the entry for:

1. Initial Services Plan dated:

(i) August 29, 2025 (client file numbered 2);

2. Comprehensive Assessments dated:

(i) December 22, 2025 (client file numbered 1); and

(ii) August 18, 2025 (client file numbered 2);

3. Treatment Plans dated:

(i) January 26, 2026 (client file numbered 1); and

(ii) August 25, 2025 (client file numbered 2);

4. Documentation of treatment services dated:

(i) January 2, 9, 13, 15, 26, 2026 (client file numbered 1);

(ii) August 18, October 9, and 16, 2025 (client file numbered 2); and

(iii) January 26, 2026 and February 2, 2026 (client file numbered 4);

5. Treatment Plan Reviews dated:

(i) February 2, 2026 (client file numbered 1); and

(ii) October 13, 20, and 26 2025 (client file numbered 2);

6. Discharge Summary dated:

(i) January 28, 2026 (client file numbered 2): and

d. Documentation of a treatment services was not signed within seven days of providing the treatment service on February 4, 2026 (client file numbered 4).

Statute Violated: Minnesota statutes, sections 245G.06, subdivisions 2a and 2b, paragraph (c) and 245G.07, subdivision 4, paragraph (c), clause (2).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that documentation of treatment services meets all applicable requirements.

16. Violation: One of five client files reviewed for requirements governing services provided via telehealth (client file numbered 3) did not meet requirements. Documentation for services provide on January 19, 2026, did not include the following:

a. The license holder’s basis for determining that telehealth is an appropriate and effective means for delivering the treatment service;

b. The mode of transmission used to deliver the service through telehealth; and

c. The location of the originating and distance site.

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 documentation telehealth services meet all applicable requirements.

17. Violation: Three of four client files reviewed for requirements governing treatment plan reviews (TPR) did not meet requirements in the following way:

a. The TPR did not contain the accurate time span covered by the review for:

1) TPR’s signed January 29, 2026, and February 2, 2026 (client file numbered 4);

2) TPR’s signed July 18, 2025, July 25, 2025, and August 1, 2025 (client file numbered 5);

3) TPR signed February 5, 2026 (client file numbered 1); and

4) TPR’s signed October 17, 2025, October 19, 2025, and October 30, 2025 (client file numbered 2); and

b. The TPR did not contain toxicology results for July 15, 2025 (client file numbered 5)

Statute Violated: Minnesota statutes, section 245G.06, subdivision 3, clause (2).

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that client record documentation meets all applicable requirements.

18. Violation: One of five client files reviewed for requirements governing record keeping (client file numbered 1) did not meet requirements. The client record was not protected against unauthorized disclosure according to section 254A.06, chapter 13, and Code of Federal Regulations, title 42, chapter 1, part 2, subpart B, sections 2.1 to 2.67, and title 45, parts 160 to 164. Disclosure was made to probation on January 2 and 9, 2026. The release of information was signed on January 13, 2026.

Statute Violated: Minnesota statutes, section 245G.09, subdivision 1.

Corrective Action Required: Immediately and on an ongoing basis, the license holder must ensure that record keeping meets all applicable requirements.

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 carrie.salsness@state.mn.us or by mail:

Commissioner, Department of Human Services

ATTN: Carrie Salsness

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) 431-3815 or at carrie.salsness@state.mn.us.

Sincerely,

Carrie Salsness, Licensor

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/