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Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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1/17/19  4:53 pm
Commenter: Jane Yaun, RACSB and chair of VACSB regulatory committee

SC Guidance Manual

Thank you for the opportunity to comment. on this manual.  As said by others, it is obvious much effort was out into gathering information regarding the dutie and responsibilities of support coordinators.  My concerns are as fllows:

1) Manual is cumbersome with many internal links, will not be user-friendly and therefore will likely not get used.

2) Information in manual is repetitive and many pages could be out-of-date before it is published - who will keep it updated.

3) Information may be better divided with use of appendices and items noted for hisotrical reference vs. information needed for current operations.  In addition clarity is requested re:

p 52 - No definition of "short term  or special need" as it relates to targeted case management

page 71 - defintiion needed for injury, serious injuries and crisis - assumption made that it will follow OHR definitions?

p80 and p824 - One page notes determination of stable for  enhanced case management purposes require documentation by licensed medical professional - but not stated on subsequent pages.  Clarity needed

p326 - should second line read "FIS" waiver vs "IS" waiver?

p 327 and 381 - different instructions re: what to do when a slot is available - p327 says CSB contacts WSAC facilitator, p 381 states CSB will contact regional support specialist

p 331 - need clarity around service authorization requests currently reads "SC completes SAs for environmental mods, PERS and assistive technology as the provider".  What about CSBs that do not provide this service?   What about providers who provide these services and have an NPI number and bill for these services?

Thank you for the opportunity to comment