In Wisconsin

Under Wisconsin regulations, SUD facilities must coordinate with medical providers when a patient has medical needs that the facility cannot meet. This includes making sure the patient can receive prescribed infusion or injection medications—either by helping the patient self-administer or by arranging outside medical support if staff are not trained to do it.

SUD facilities must also have written policies to ensure they do not deny services or discriminate against someone because of a disability, including a bleeding disorder. These policies must follow federal disability laws such as Section 504 of the Rehabilitation Act, which requires facilities to conduct an individualized assessment during admission rather than denying someone automatically because of their condition.

However, staff from the Wisconsin Department of Human Services (DHS), Division of Quality Assurance, have clarified that the state does not enforce this requirement. If a facility denies someone admission because of a disability like a bleeding disorder, DHS does not consider it a violation of state code.

Sources:

• (19) MEDICAL SERVICES.

  (19) Medical services. (c) For medical needs of a patient that exceed the scope of the service under this chapter, the service shall coordinate with appropriate medical providers.

• DHS 75.14(4)a Prevention service. 3(b) 3. Establish written policies and procedures for the operation of the service and exercise general direction over the service, to ensure the following: b. That no person will be denied service or discriminated against on the basis of sex, race, color, creed, sexual orientation, disability, or age, in accordance with 45 CFR part 92 and Title VI of the Civil Rights Act of 1964, as amended, 42 USC. 2000d, Ti- tle XI of the Education Amendments of 1972, 20 USC 1681- 1686 and s. 504 of the Rehabilitation Act of 1973, as amended, 29 USC 794, and the Americans with Disabilities Act of 1990, as amended, 42 USC 12101-12213. 

• DHS Division of Quality Assurance; via meeting on June 16, 2025

• “Under Wisconsin regulations, SUD facilities must coordinate services with appropriate medical providers when a patient has medical needs the facility can’t fully handle. This includes helping the patient receive prescribed medications—like infusion or injection treatments—if your staff aren’t trained to give them or if [patient name] can’t self-administer. “

• “[Patient name] has a well-managed, stable bleeding disorder, and the regulations say that medical needs like this should not be a reason to deny admission.”

• “SUD facilities must also have written policies that make sure no one is denied care or discriminated against because of a disability, including a bleeding disorder. These policies must follow federal disability laws such as Section 504, which prohibits denying someone based on disability alone and requires an individualized assessment during the admissions process.”

• “I completely understand that bleeding disorders can sound complicated — they’re rare, genetic conditions that most behavioral health providers don’t encounter often. That unfamiliarity can understandably make it seem like these patients need a high level of medical support. In reality, national guidance makes clear that for individuals who are medically stable, their bleeding disorder can be managed safely within your setting without intensive medical intervention.”

• “National guidance from the National Bleeding Disorders Foundation’s Medical and Scientific Advisory Council (known as MASAC) is very clear on this point. MASAC has formally stated that if a person with a bleeding disorder is medically stable and has an established treatment plan from their hematologist, their day-to-day management is straightforward and not complex.”

• “In other words, as long as my patient is permitted to continue their prescribed bleeding disorder medication during admission, they are not medically complex, and their diagnosis alone should not be a reason for exclusion from treatment.”

• “MASAC guidance (Document #289, approved October 2024) specifically notes that stable individuals with bleeding disorders typically manage their condition independently in the community. They don’t need hospitalization, remote monitoring, or special medical supervision. The presence of a bleeding disorder alone does not make someone medically unfit or unstable for behavioral-health admission.”

• “If any unrelated medical issue were to arise during treatment, the facility should simply follow its usual standard of care, just as it would for any other patient.”

• “I’m happy to send you the full MASAC recommendation from the national experts and walk through any questions you might have.”

Send the following to the facility:

• Accessing Care for [Patient name]: Personalize this template to facilitate access to care in a substance use disorder facility.