Commenter:
Jane Yaun, Rappahannock Area Community Services Board
CMHRS regs
An exclusion has been added to include MH supervised living to those facililties which cannot receive MHSB from the “owner” of the supervised living site. The addition of supervised living into language affects those of us who own apartment buildings and provide MHSB. Would directly impact current programs and decrease community services available to those discharging from facilities. Ww would be unable to continue to operate a CSB owned 24 hour program that has been in existence over 15 years, which was originally designed to assist in hospital discharge planning.
Chapter II, page 16
Concerned that Certified Peer Specialists are not listed as allowable providers of CMHRS services (psychosocial, crisis, MHSS, etc.
Clarity is needed around the comprehensive needs assessment and how it differs from the case management needs assessment - which is not required to be completed by an LMHP or LMHP-type. Further, it is much appreciated that the effort has been made to streamline when the needs assessment is completed; however, there seems to be some contradicting information. For example, on page 18, the language contradicts the need for one assessment by saying: “A comprehensive needs assessment must be completed prior to initiating each of the following services:
Intensive In-home Services for Children and Adolescents
Therapeutic Day Treatment for Children and Adolescents
Mental Health Crisis Intervention* (only if an ISP is developed: refer to service details)
Mental Health Crisis Stabilization
Mental Health Day Treatment/Partial Hospitalization Services
Psychosocial Rehabilitation
Intensive Community Treatment
-Please clarify age restrictions for QMHP- A and QMHP-C
We are concerned that counseling has been addeded to the required services for ICT without further clarification of where that counseling needs to occur and how often. We do not have enough licensed or licensed -type staff to meet the defintion of counseling and this could pose a barrier to access of services.
Chapter II, page 9 - reporting of knowledge of adverse outcomes up to 180 days post discharge is difficult if not impossible given the number of individuals served by the CSB.
