1 comment and 1 question:

Regs state Providers must report any knowledge of adverse outcomes for an individual currently receiving services or who have been discharged from services within 180 days of the incident.

Comment: It is not within the means of a provider to continue to be aware of or track adverse events of consumers once they have been discharged from services . This requirement puts an unjust burden on the provider and will likely be a requirement that the provider will always be out of compliance. It would make better sense to have this be an expectation of the Care Coordination activities of the Health Plans.

Question: Based on the additional language added that addresses physician directed services and Community Mental Health Clinics, it appears that the current MH Clinic Manual will likely be retired effective 08/01 and all psychaitric services will fall under the Psychiatric Manual effective 08/01. Is this accurate?  If this is accurate, are there any contracting implications ? Will this affect any current contracts based on whether, as an agency, we are contracted as physician directed under the current MH Clinic Manual or contracted as not under the current Psychiatric Manual? Please clarify and advise.