Chapter II

1. Pg. 16, Adverse Outcomes: Suggest that the reporting requirements align with the DBHDS serious incident reporting requirements which do not require providers to report incidents for individuals who have been discharged from their services.  Providers should not be required to monitor and report adverse outcomes for individuals who have been discharged from their services. The treatment relationship has ended and reporting incidents would be a violation of the individual’s privacy.

2. Pg. 14, Provider Qualifications for OP Psychiatric Services: DMAS allows LMHP-Rs, LMHP-Ss, and LMHP-RPs to provide OP Psychiatric Services under the direct supervision of an LMHP. However, not all the Medicaid MCOs allow or reimburse for services provided by an LMHP-R, LMHP-S or LMHP-RP under the LMHP, unless the provider is with a CSB. Would recommend that language be included in this Manual to refer providers to the MCO before utilizing LMHP-R, LMHP-S, or LMHP-RP to provide OP services.

3. Page 15, Mental Health Clinic requirements:  Including the Mental Health Clinic provider manual information into the Psychiatric Services Manual is now confusing.  Perhaps some language could be added to differentiate between what qualifies as a Mental Health Clinic versus a group OP practice/agency providing OP Psychiatric Services?

Chapter IV

1. Page 31 – If OP psychiatric services will now be allowed to be provided in the school setting to cover the counseling component of the TDT program, suggest adding the school as an allowed place of service.

2. Page 31 – Including the Mental Health Clinic requirements under the OP Psychiatric Services section is very confusing and implies that all OP providers are subject to these physician-directed requirements. Perhaps the Mental Health Clinic specific information could be moved to its own section.

3. Page 37 – “The individual must participate and be compliant with treatment (e.g. some individuals with intellectual disabilities [ID] or children may not have the ability to understand the treatment).”.  In the Psychiatric Services Provider Manual, it indicates that children may not have the ability to understand the treatment of OP psychiatric services, yet in the CMHRS Provider Manual, individual, group and/or family counseling, which can be provided through Outpatient psychiatric services, are a REQUIRED component of the services provided to children (TDT and IIH specifically) and providers can be cited for not providing those components of the CMHRS services. There seems to be a contradiction here on whether counseling/OP psychiatric services are appropriate for children.  In all cases, shouldn’t clinical necessity and appropriateness of the service be determined by the LMHP completing the Assessment or Diagnostic Interview? Can this be clarified in both manuals?

4. Page 39, Telemedicine Services:

   • The LMHP-R, LMHP-S, and LMHP-RP are not listed as eligible “remote providers” in the May 13, 2014 Medicaid Memo.  As the Psychiatric Services Manual includes these as Providers, under the supervision of the LMHP, can they also provide Telemedicine Services?  Please clarify here or perhaps updates are needed to the May 13, 2014 Memo.

   • “Schools” are not listed as an approved “originating site” in item g. of Attachment A of the May 13th Memo.  If DMAS is going to allow the school-setting to be a reimbursable setting for OP Psychiatric Services to cover the counseling component of the TDT service, can it also be an approved “originating site” for the use of Telemedicine?

5. Care Coordination – Recommend that some language be included on the requirement for Care Coordination with any concurrent CMHR and other services.  Counseling is a required component of many of the CMHR services which may be provided as OP services and if OP providers are not obligated to coordinate services with other providers this may impede the CMHRS provider’s ability to comply with their requirements for care coordination.

Chapter VI

1. Page 4, Notes for therapy sessions: The first paragraph indicates that if the therapy session was conducted by a Resident of Supervisee, the progress note must be signed by the LMHP on the same day as the therapy session. The last paragraph indicates the note must be signed within one-business day from the date of service. Please correct for consistency.

2. Can the Comprehensive Needs Assessments, described in the CMHRS Provider Manual, be utilized as, or in lieu of, the Psychiatric Diagnostic Evaluation/Interview for OP Psychiatric Services?