Comprehensive Needs Assessment – From a parent/grandparent perspective, the required repeated repetition of the entire Comprehensive Needs Assessment within a service setting and across service settings is not only time consuming (for the family and the providers), but was also traumatic for our family us as my son had to talk about his brother’s suicide each time an assessment was done.  There was no reason that most of the information on the Comprehensive Needs Assessment needed to be repeated. In addition, I didn’t see anything on the CNA that would guide providers to explore the possibly of childhood trauma, or the possibly of sensory or auditory sensitivities that could be setting off behavior issues.

Medical Necessity Criteria for IIH Individuals receiving IIH Services must have the functional capability to understand and benefit from the required activities and counseling of this service.  These services are rehabilitative and are intended to improve the individual’s functioning.  It is unlikely that individuals with severe cognitive and developmental delays/impairments would clinically benefit and meet the service eligibility criteria. 

In light of what we continue to learn from adults who were diagnosed with severe disabilities due to their inability to communicate, but who were actually very intelligent, I hope that this criteria will be re-evaluated.  Even for those children who truly do have severe cognitive and developmental delays, their parents need guidance on how to deal with the real-life situations that occur in the home. Our focus needs to be on equipping providers with the skills to help these individuals and their families, not on denying services to these individuals whose dual diagnoses make them too difficult for our systems to meet their challenges.

Chapter IV, Page 43: Service provider care coordination including consultation, collaboration, and coordination with teachers, concurrent service providers, and others involved in the individual’s treatment to include scheduling appointments and meetings to improve care; planning and implementing individualized behavior modification programs; and monitoring treatment and ISP progress. The provider will be asked to explain what care coordination has taken place during treatment as well as in preparation for discharge and step down to lower levels of care with every request for services.

Behavior Modification is a form of treatment designed to make the individual conform to what others would like to see – often without fully understanding the underpinnings of the individual’s reasons for their unusual or “unacceptable” behavior.  I would love to see DMAS move to evidence based relationship-based, methods of supporting and helping neuro-diverse individuals.  Please see:  https://www.monadelahooke.com/new-lens-understanding-behavior-problems/  and https://www.monadelahooke.com/consider-starting-childhood-behavioral-therapies/

Providers – it appears that all of the case management must be done by CSB or BH (state) employees.  Is that correct? What is the rationale for this?  It wasn’t as clear to me about the role of private mental health providers.  I hope that the regulations will provide for ease of participation of ALL providers (public and private) with smooth interaction and communication between the two groups for the benefit of the families served. 

http://townhall.virginia.gov/L/entercomment.cfm?generalnoticeid=858