What domains must an ARMHS functional assessment cover?

Minn. Stat. § 245I.10, subd. 9 requires an adult functional assessment to document how the client's mental illness symptoms affect functioning in ten areas: mental health symptoms; mental health service needs; substance use; vocational and educational functioning; social functioning including leisure time; interpersonal functioning including family and natural support relationships; ability to provide self-care and live independently; medical and dental health; financial assistance needs; and housing and transportation needs. Each area needs a written narrative, and a validated tool such as the DLA-20 may be used alongside it.

How often must an ARMHS functional assessment be updated?

Under § 245I.10, subd. 9, the functional assessment must be updated with the client's current functioning whenever there is a significant change in functioning, or at least every 365 days, unless a specific service rule says otherwise. It must also be completed before the client's initial individual treatment plan. In practice most ARMHS agencies update the functional assessment at the same time as a treatment plan review so the plan goals stay tied to current functioning.

How often does an ARMHS treatment plan have to be reviewed?

Minn. Stat. § 245I.10, subd. 8 requires the license holder to review the individual treatment plan every 180 days and update it with the client's treatment progress and new objectives and goals, or, if the client has not made progress, with changes in the provider's approach. The review must be dated and signed. Services billed after a plan has gone more than 180 days without a documented review are at risk of recoupment because the plan is no longer current.

What is the most common ARMHS functional assessment mistake?

Scoring a domain without writing a narrative. A number on a rating scale tells a reviewer nothing about how symptoms affect the person's daily functioning or what a treatment goal should address. The second most common mistake is a functional assessment that was completed without documented input from the client's family or natural supports and without a note explaining why they were not contacted. Both leave the treatment plan without a foundation.

ARMHS functional assessment and treatment plan: timelines and mistakes

Short answer

An ARMHS functional assessment must be completed after the diagnostic assessment and before the initial treatment plan, using a collaborative process that gathers input from the client, family, natural supports, referral sources, and providers, and it must document how mental illness symptoms affect functioning in the ten areas listed in Minn. Stat. § 245I.10, subd. 9. Adult providers must also complete a level of care assessment (LOCUS). The individual treatment plan built from it must be approved by the client, approved by a supervisor within ten business days when written by a practitioner or trainee, and reviewed every 180 days.

Key takeaways

The functional assessment comes after the diagnostic assessment and before the initial individual treatment plan, and must be updated on significant change or at least every 365 days.
Minn. Stat. § 245I.10, subd. 9 names ten functional areas; each needs a narrative on how symptoms affect functioning, not just a score.
ARMHS eligibility under § 256B.0623 requires substantial disability and functional impairment in three or more of those areas, so the assessment narrative is also the eligibility evidence.
When an ARMHS provider completes a functional assessment, it must also complete a level of care assessment; for adults that is the LOCUS.
A treatment plan written by a practitioner or clinical trainee must show supervisor approval within ten business days, and every plan must be reviewed every 180 days.
The client must approve the plan; if they disagree, the reasons go in the file, and a mental health professional must seek approval from an authorized person within 30 days after the previous plan expired.

The ARMHS functional assessment is the document that makes everything after it defensible. Adult Rehabilitative Mental Health Services (ARMHS) exist to address functional impairments caused by mental illness, and Minn. Stat. § 245I.10, subd. 9 requires the assessment to show, domain by domain, what those impairments are. The individual treatment plan (ITP) turns those findings into goals, and every progress note points back to a goal.

Department of Human Services (DHS) reviewers read the chain in that order: diagnostic assessment, functional assessment, level of care, treatment plan, notes. A weak functional assessment makes the plan look unsupported and the notes look unnecessary.

This guide covers what the functional assessment must contain and who must contribute to it, how it feeds the level of care determination and the treatment plan, what the plan must contain and who signs it, the timelines DHS checks, and the mistakes that show up most often. It reflects the rules as of September 2026. The ARMHS documentation requirements checklist covers the rest of the client record.

What § 245I.10, subd. 9 requires in a functional assessment

For an adult functional assessment, the license holder must:

Complete it after the diagnostic assessment.
Use a collaborative process that lets the client, the client's family and other natural supports, referral sources, and other providers contribute information about how symptoms affect functioning.
Document the reasons if family and natural supports were not contacted.
Assess and document how symptoms of mental illness affect functioning in ten areas.
Complete it before the initial individual treatment plan, unless a specific service says otherwise.
Update it whenever there is a significant change in functioning, or at least every 365 days.

The statute also allows any validated measurement tool, and names the Daily Living Activities-20 (DLA-20) as an example. A tool alone is not sufficient; the requirement is to document impact on functioning, which means a narrative for each area.

The ten domains

#	Domain	What the narrative should say
1	Mental health symptoms	Which symptoms are present and how they show up day to day
2	Mental health service needs	What services the person needs and is receiving
3	Substance use	Current use and how it interacts with functioning
4	Vocational and educational functioning	Work or school status and what symptoms get in the way
5	Social functioning, including leisure time	How the person spends unstructured time and with whom
6	Interpersonal functioning, including family and natural supports	Quality of relationships and where conflict or isolation occurs
7	Self-care and independent living	Hygiene, meals, medication routines, household tasks
8	Medical and dental health	Conditions, appointments kept or missed, and barriers
9	Financial assistance needs	Income, benefits, budgeting, and money-related stressors
10	Housing and transportation needs	Stability of housing and how the person gets around

Each narrative should name the strength, the challenge, and the resource in that domain, in the person's own situation. "Moderate impairment" is a score. "Misses about half of scheduled medical appointments because anxiety makes phone calls and bus travel difficult; sister will drive when asked" is a narrative that can become a goal.

Why the domains also decide eligibility

Under § 256B.0623, subd. 3, an eligible ARMHS recipient is 18 or older, has a diagnosis for which ARMHS is needed, has a recent standard diagnostic assessment documenting that ARMHS is medically necessary, and has substantial disability and functional impairment in three or more of the areas listed in § 245I.10, subd. 9. The functional assessment is therefore the eligibility evidence as well as the planning document. If fewer than three domains show substantial impairment in the narrative, the reviewer will ask why the person is receiving ARMHS at all. The ARMHS eligibility guide maps each criterion to its evidence, and the plan frequency you write from the assessment must fit the January 1, 2027 hour caps explained in the ARMHS 2027 changes guide.

Compliance note: "input from natural supports" has to be visible. If a sister, roommate, or case manager contributed, name the source and date in the assessment. If nobody could be reached or the client declined, write that down. A functional assessment with no third-party input and no explanation is a routine finding.

Level of care: LOCUS and the § 256B.0623 link

§ 256B.0623, subd. 9 requires that when an ARMHS provider completes a written functional assessment, it must also complete a level of care assessment as defined in § 245I.02, subd. 19: the level of care decision support tool appropriate to the client's age. For adults that is the Level of Care Utilization System (LOCUS).

Record the score, the resulting level, the date, and the credentials of the person who completed it, then compare it with the plan. A minimal-support level alongside several contacts a week is not automatically wrong, but the plan should explain the difference. The level of care assessment is also one of the four documents that need supervisor approval within ten business days under § 245I.08, subd. 3.

How the functional assessment feeds treatment plan goals

The plan is written from the domains where the assessment found substantial impairment. Draw a line from each impaired domain to at least one goal, and from each goal back to a domain. A goal with no domain is unsupported; an impaired domain with no goal needs a documented reason it is not being addressed now.

A worked chain for a fictional client, J.:

Domain 9, financial assistance needs (narrative): J. receives SSI and has been late on rent three of the last six months because money runs out mid-month; J. wants to stop worrying about eviction.
Goal 2 (in J.'s words): "I want to pay my rent on time every month."
Objective 2a (measurable, dated): J. will track spending for one week using a budget worksheet and identify two expenses to reduce, by October 15, 2026.
Intervention: Weekly individual basic living skills sessions in J.'s apartment; staff model and practice a Friday budget check; MHRW delivers, clinical supervisor co-signs.
Frequency: One contact per week, up to four units each.

Every progress note for that goal then names Goal 2 and Objective 2a. The progress note guide shows a full example note built on this chain.

What the individual treatment plan must contain and who signs it

§ 245I.10, subd. 8 sets the required elements. After the diagnostic assessment and before services beyond those allowed under subd. 7, the license holder must:

Base the plan on the diagnostic assessment and baseline measurements (the functional assessment and LOCUS are the baseline for ARMHS).
For an adult, use a person-centered, culturally appropriate planning process that lets the client's family and natural supports observe and participate.
Identify treatment goals, measurable objectives, a schedule for accomplishing them, a treatment strategy, and the individuals responsible for providing services and supports.
Identify the participants in planning. The client must be a participant, and the file must say why family or natural supports were not involved if they were not.
Review the plan every 180 days and update it with progress, new objectives and goals, or, if there has been no progress, changes in the approach to treatment.
Ensure the client approves the plan, unless a court orders treatment under chapter 253B.

If the client disagrees with the plan, the reasons go in the file. If the client's approval cannot be obtained, a mental health professional must make efforts to obtain approval from a person authorized to consent on the client's behalf within 30 days after the previous plan expired. The provider may not deny service during that period solely because approval is missing.

For a plan discussed by telehealth, the MHCP telehealth policy allows the provider to document the client's verbal or electronic written approval in place of a signature. Record it in the note and on the plan.

Supervisor approval within ten business days

Under § 245I.08, subd. 3, a diagnostic assessment, functional assessment, level of care assessment, or treatment plan completed by a clinical trainee or practitioner must contain documentation of approval by the treatment supervisor within ten business days of initial completion. The approval needs a date and credentials, or it cannot show the ten-day rule was met.

Timelines DHS checks

Item	Timeline	Source
Functional assessment	After the diagnostic assessment and before the initial ITP	§ 245I.10, subd. 9
Functional assessment update	On significant change, or at least every 365 days	§ 245I.10, subd. 9
Level of care assessment	Completed with the functional assessment	§ 256B.0623, subd. 9
Supervisor approval of DA, FA, level of care, or ITP by a practitioner or trainee	Within 10 business days of completion	§ 245I.08, subd. 3
Treatment plan review	Every 180 days	§ 245I.10, subd. 8
Substitute approval when the client cannot approve	Efforts within 30 days after the previous plan expired	§ 245I.10, subd. 8

The ARMHS billing guide explains how a pre-claim check catches lapsed assessments and plans before submission.

Common functional assessment and treatment plan mistakes

Scores without narratives. The most frequent finding. Each of the ten domains needs prose on how symptoms affect functioning.
No natural support input and no explanation. The collaborative process must be visible.
Fewer than three substantially impaired domains. Eligibility under § 256B.0623, subd. 3 is not shown.
Plan written before the functional assessment. The order in § 245I.10, subd. 9 is DA, then FA, then ITP.
Goals that do not trace to a domain. Generic goals ("improve independent living skills") with no measurable objective or date.
Missing or undated supervisor approval. Or an approval more than ten business days after completion.
Plan review past 180 days.
No client approval and no documented reason. A signature line left blank with nothing in the file.
Level of care missing or inconsistent with the plan. LOCUS not completed with the FA, or a level that contradicts the service intensity without explanation.
Functional assessment older than 365 days.

Most of these are process failures, and a system that enforces the order and the dates removes them. The ARMHS software buyer's guide lists the specific enforcement to ask for.

How Trustora helps

Trustora's ARMHS record enforces the assessment chain in statutory order. A functional assessment form carries all ten § 245I.10, subd. 9 domains with a required narrative in each, a field for who contributed and when (or why natural supports were not contacted), and an attached level of care assessment. A treatment plan cannot be finalized until the diagnostic assessment and functional assessment are current, and each goal must be linked to an assessed domain with a measurable objective and target date.

Supervisor approvals are tracked against the ten-business-day rule, plan reviews against 180 days, and functional assessment updates against 365 days, with alerts before each deadline. Client approval, disagreement reasons, and telehealth verbal approval are recorded on the plan itself. See the platform overview for the assessment and treatment planning workflow.

Frequently asked questions

What domains must an ARMHS functional assessment cover?: Minn. Stat. § 245I.10, subd. 9 requires an adult functional assessment to document how the client's mental illness symptoms affect functioning in ten areas: mental health symptoms; mental health service needs; substance use; vocational and educational functioning; social functioning including leisure time; interpersonal functioning including family and natural support relationships; ability to provide self-care and live independently; medical and dental health; financial assistance needs; and housing and transportation needs. Each area needs a written narrative, and a validated tool such as the DLA-20 may be used alongside it.
How often must an ARMHS functional assessment be updated?: Under § 245I.10, subd. 9, the functional assessment must be updated with the client's current functioning whenever there is a significant change in functioning, or at least every 365 days, unless a specific service rule says otherwise. It must also be completed before the client's initial individual treatment plan. In practice most ARMHS agencies update the functional assessment at the same time as a treatment plan review so the plan goals stay tied to current functioning.
How often does an ARMHS treatment plan have to be reviewed?: Minn. Stat. § 245I.10, subd. 8 requires the license holder to review the individual treatment plan every 180 days and update it with the client's treatment progress and new objectives and goals, or, if the client has not made progress, with changes in the provider's approach. The review must be dated and signed. Services billed after a plan has gone more than 180 days without a documented review are at risk of recoupment because the plan is no longer current.
Who has to approve an ARMHS treatment plan and how quickly?: Two approvals apply. The client must approve the plan under § 245I.10, subd. 8, unless a court orders treatment under chapter 253B; if the client disagrees, the file must document why. Separately, under § 245I.08, subd. 3, a diagnostic assessment, functional assessment, level of care assessment, or treatment plan completed by a clinical trainee or practitioner must contain documentation of approval by the treatment supervisor within ten business days of initial completion.
Is LOCUS required for ARMHS in Minnesota?: Yes for adults. Minn. Stat. § 256B.0623, subd. 9 states that when an ARMHS provider completes a written functional assessment, it must also complete a level of care assessment as defined in § 245I.02, subd. 19, which is the level of care decision support tool appropriate to the client's age. For adults that tool is the Level of Care Utilization System (LOCUS). Document the score, the resulting level, the date, and who completed it, and keep it consistent with the intensity of service on the plan.
What is the most common ARMHS functional assessment mistake?: Scoring a domain without writing a narrative. A number on a rating scale tells a reviewer nothing about how symptoms affect the person's daily functioning or what a treatment goal should address. The second most common mistake is a functional assessment that was completed without documented input from the client's family or natural supports and without a note explaining why they were not contacted. Both leave the treatment plan without a foundation.

Sources and further reading

Cite this article

Trustora Editorial Team. (2026, September 4). ARMHS functional assessment and treatment plan: timelines and mistakes. Trustora. https://trustora.com/blog/armhs-functional-assessment-and-treatment-plan-guide

ShareLinkedIn X Facebook Email

This article is general information for Minnesota agencies, not legal, clinical, or billing advice. Minnesota DHS policy changes often. Confirm current requirements in the MHCP Provider Manual, the Minnesota Statutes, and DHS provider notices before acting on anything here.