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August 10, 2026 CERTIFIED MAIL Eve-Lynn Fellersen, Authorized Agent Two Rivers Counseling LLC 222 W Superior Street, Suite 200 Duluth, MN 55802 License Application Number 1126108 (245G) ORDER OF LICENSE DENIAL Dear Eve-Lynn Fellersen: The Department of Human Services (DHS) is denying your application for a substance use disorder (SUD) treatment program license at 222 W Superior Street, Suite 200, Duluth, MN 55802. This denial is based on failure to demonstrate competent knowledge of applicable licensing statutes and rules and failure to submit 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. Failure to submit a substantially complete application You submitted an application for a license to provide substance use disorder treatment services at 222 W Superior Street, Suite 200, Duluth, MN 55802. A DHS licensor reviewed your full policy and procedure manual and determined that the manual was substantially incomplete. On April 16, 2025, a video call with the 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 a detailed checklist outlining areas of noncompliance. On June 18 and November 6, 2025, after reviewing subsequent application submissions, video calls with the DHS licensor were conducted to explain items that remained missing and/or out of compliance with application requirements. On March 11, 2026, a video call with the DHS licensor was conducted to identify outstanding items requiring correction or additional information to satisfy applicable application requirements. This information was also provided to you in writing in the Notice of Incomplete Application, along with a detailed checklist outlining areas of noncompliance. It was determined that your application was substantially incomplete in the following ways: · 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 Table of contents o Service initiation o Service termination o Treatment services description, including amount and type of services provided o Telehealth policy o Program abuse prevention plan o Plan for transfer of clients and records upon closure, including a signed agreement o Personnel Policies: § Job descriptions § Organizational chart § Orientation · A Signed agreement indicating that a county or a similarly licensed provider has agreed to accept and maintain the program's closed case records and to provide follow-up services as necessary to affected clients was not included. On March 30, 2026, DHS sent you a Notice of Incomplete Application via certified mail, notifying you that your application was incomplete and that you had 45 days from your receipt of the notice to submit additional information. You signed the certified mail on April 2, 2026. DHS Licensing did not receive your revised policies and procedures manual within the required time frame. The DHS licensor attempted to contact you by phone and email on May 19, 2026, and by phone on July 6, 2026; however, the licensor did not receive a response. Legal Authority: 245A.05, subdivision (a)(1). 2. Failure to 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. 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. Throughout the application process, multiple policies and procedures in your application were not updated based on the feedback provided. Your inability to follow the laws and rules during the application process makes it less likely you will be able to do so when operating a substance use disorder treatment program. 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 program’s 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. 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 revoke a license. · “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 Kathryn Schesso, Supervisor, at 651-431-2734. Sincerely,
Katie Leuer, Unit Manager Licensing Division Office of Inspector General
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