Chapter II

1.       Pg. 6 – “Additionally, any licensed practitioner joining a contracted group practice or a contracted organization adding a newly licensed location must also become credentialed with Magellan of Virginia and/or a Medicaid MCO prior to rendering services.” 

•  Do LMHPs in a group practice who only provide CMHRS need to be separately credentialed and contracted with the BHSA and MCOs since CMHRS services are not billed under their individual NPI numbers?   With most MCOs, as long as Staff Rosters are updated, no separate credentialing is required unless the licensed practitioner is also providing Outpatient Psychiatric services.
• Not all MCOs require each new location to be separately credentialed and contracted as long as the provider submits updated DBHDS licenses and updates sites/location information with the MCO.  Perhaps this language should be modified to refer the providers to their contracts with the MCOs for the specific requirements instead of making a blanket statement.

2.       Pg. 9 – 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 responsible for reporting 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. 

3.       Pg. 12 – Definition of “QMHP-A”.  Suggest defining the age range of the individuals that the QMHP-A may provide services to, just as it was for the QMHP-C definition. 

4.       Pg. 13 – Definition of “QMHP-C”.  Is “under the age of 22” correct?  12VAC30-50-130.B.5(a) defines adolescent or child through the age of 20, not 21.  Also see definition in Chapter IV.

5.       Pg. 13 – Is the DMAS/DBHDS approved monthly training no longer required for a QMHP-Eligible (Trainee)?

6.       Pg. 15 – IIH Provider Requirements.  Can LMHP-R, LMHP-S, LMHP-RP provide clinical oversight of the IIH program? DBHDS regulation 12VAC35-105-590.C.5 allows “LMHP-eligibles” to provide clinical supervision for IIH services.

7.       Pg. 15 – TDT Provider Requirements – “Providers must have a non-school based TDT license with DBHDS to provide non-school based TDT which includes summer school.”  Summer school provided during school-sponsored summer school programming is licensed and provided under the provider’s school-based TDT license, not non-school based (verified through the DMAS CCC+ Provider Call).  Suggest making sure the descriptions for “School-Based” and “Non-School Based” TDT services align with the DBHDS descriptions of these two separate licenses.  Also see the information in the Exhibit in Chapter IV.

Chapter IV

1.       Pg. 9, definition of “Crisis Treatment” -  May need to differentiate ‘crisis treatment’ which is generally a component of some CMHRS and ‘Crisis Intervention (H0036)’ which is itself a CMHRS.

2.       Pg. 11, definition of “Medication Management”

• Page 25 indicates that Medication Management may only be provided by an LMHP-type, but it is not in the definition.   It is only implied since it is defined as “counseling”. 
• Please note that the Board of Counseling includes medication management as a service that can be provided by a QMHP-C.  See the Board’s QMHP FAQs (6.2018) page 9, QMHP-C can provide “Medication education and management”.  Request that DMAS reconsider their exclusion of QMHPs from providing ‘medication management’ or modify the definition so that it does not conflict with the Board’s directive that QMHPs can provide this component of services.

3.       Pg. 12, definition of “QMHP-C” -  “A QMHP-C may only provide services to individuals under the age of 22”.  Is 22 correct?  See definition of “Adolescent or child” on page 6.

4.       Pg. 13, definition of “QMHP-A” - Recommend defining the the age range for “adults”. 

5.       Pg. 18 – Comprehensive Needs Assessment (CNA).

• There is no guidance provided on how to bill the Comprehensive Needs Assessment for multiple services.    Currently, the BHSA will not process claims for services until a claim for the service-specific Assessment has been processed and paid.  How do we bill a single CNA for multiple services?  Please provide the billing requirements/codes associated with the Comprehensive Needs Assessment for multiple services vs a service-specific Assessments and the maximum number per year allowed.
• Is there a certain timeframe within which the initial CNA can be amended to include additional needed services or when a separate CNA is needed to initiate an additional service?  30 days, 60 days, 90 days? 

6.       Pg. 22 – ISPs.  Chapter VI – Utilization Review, page 13 indicates that all ISPs have to be completed within 30 days of the date of the Assessment, unless otherwise specified.  Suggest replacing the “date of initiation of services” referred to here with the same language found in Chapter 6, “within 30 days of the Assessment”.  

7.       Pg. 29 – Service Authorizations.  Appendix C, referenced here, does not provide the list of services that require Authorization vs Registration.  Would recommend, however, that the list of those services be retained as part of Chapter 4.  Provides a quick reference for providers of services that need authorization vs registration, instead of having to refer to another chapter in the manual to get the information.

8.       Pg. 32 – “To determine if the individual meets at-risk of hospitalization… must complete the at-risk of physical injury form (DMAS-P502)”.  Should this say “to determine if the individual meets criteria (i) of the at-risk of hospitalization”?  There are other criteria in the definition that would not require form DMAS-P502 to be completed.  Needs clarification.  Also see the “At Risk of Physical Injury” requirements on page 26.  Is this the same screening?  Please clarify.

9.       Pg. 36 – “IIH may not be billed 7 days prior to discharge from any residential treatment service or inpatient hospitalization.”  This should be clarified.  As currently understand from the BHSA, an IIH Clinical Assessment can be completed and billed in the last 7 days prior to discharge from residential treatment/hospitalization.  Is that what is being said here?

10.   Pg. 37 – “Service provider care coordination” is a Required activity per page 17. Recommend listing this under the Required Activities section, not “Additional Covered Services”.

11.   Pg. 37 – “Outpatient counseling…must be either provided by the IIH provider or coordinated with another provider…”  Since “Individual and Family Counseling” is listed as a Required service component, not sure that this is written correctly.  Is this directing that Outpatient Psychiatric Services/Therapy must also be provided by the IIH provider in addition to the Individual or Family Counseling component?  OR, is it intending to say that OP Psychiatric Services/Therapy can be provided in lieu of the Individual/Family Counseling either by the same agency or by an outside agency/provider, as long as services are aligned, addressed in the ISP, and coordinated between the OP and IIH providers?  Please clarify.

12.   Pg. 42, TDT ISP – “An ISP developed within 30 days of initiation of services…”  This should be modified to read exactly as it is written in Chapter 6 – Utilization Review, pg. 13.  “An ISP is developed within 30 days of the Comprehensive Needs Assessment”.   The “date of initiation of services” may be interpreted differently by different providers.

13.   Pg. 42, Counseling provided by OP provider - Can the OP counseling be provided in the school itself, or does this need to be provided in the OP provider’s office or clinic since a ‘school’ is not currently a billable service location for OP Therapy?  If the ‘school’ is an acceptable location for OP Therapy, can this be provided via Telemedicine?  Currently, the Medicaid Memo on Telemedicine Coverage, dated 5/13/14, doesn’t recognize a school as an allowable Originating Site for Telemedicine.  Would be very helpful if DMAS would provide more allowed/reimbursable methods of providing the counseling component.

14.   This CMHRS manual allows LMHP-S, LMHP-R or LMHP-RPs to provide the counseling component of CMHRS, where required.  However, not all Medicaid MCOs reimburse for services provided by a Resident or Supervisee under the supervision of a licensed provider, unless the provider is with a CSB.  Will reimbursement of the counseling component of a CMHR service be denied or retracted by a Medicaid MCO if it is provided by a LMHP-R, LMHP-RP or LMHP-S, under the supervision of a LMHP who is a private provider? 

15.   Pg. 67, #3, MHSS ISPs - Recommend using same language as provided in Chapter 6, pg. 12 and 13, “All ISPs shall be completed… within a maximum of 30 days of the date of the completed comprehensive needs assessment, unless otherwise specified.”  The date of the “admission to services” leaves it open to different interpretations by different providers, since the “admission date” is not defined by DMAS.

16.   Pg. 70, #9, “Only direct face-to-face contacts and services to an individual shall be reimbursable”.  Service provider care coordination is a Required component of all CMHR services (see pg. 17) and is a “covered service”  for all other services.  Request DMAS consider allowing the required care coordination to be a covered service component for MHSS as well, since not always part of face-to-face service delivery.

17.   Pg. 70, #11, MHSS supervision.  DMAS allows QMHPs to supervise the MHSS service which is inconsistent with the Board of Counseling’s directive.   Reference the Board’s QMHP FAQs dated 6.2018, pg. 8: “Supervision of collaborative mental health services must be by a licensed person or a person under supervision that has been approved by the Boards…”  The Board of Counseling does not “allow” QMHPs to supervise collaborative mental health services or QMHP-Es (Trainees).  Would be helpful if the DMAS and Board’s supervision requirements were consistent with one another.  Conflicting regulations pose difficulties for providers.

Chapter VI – Utilization Review and Control

1.       Pg. 13 – If one Comprehensive Needs Assessment has been completed for multiple services, which service-specific Assessment code is used to bill the CNA?

2.       Pg. 14 – “Service coordination between all health care service providers who are involved in the individual’s care is required and must be documented in the ISP and Progress Notes.”  Request DMAS to reconsider allowing the required service coordination be a billable component of all services.

3.       Page 14 – A “clinical supervisor” is defined here as only an LMHP-type which is not consistent with the information in Chapter IV for MHSS services.

4.       Page 14 – “For services where individual counseling is allowed for reimbursement, services must be provided face to face (including telemedicine as appropriate), one on one.”  Request that more information and/or clarification be provided on the allowable use of Telemedicine services in the delivery of the counseling component of CMHR services.  According to Medicaid Memo dated May 13, 2014, DMAS does not currently recognize Telemedicine for all CMHRS services.  In the case of TDT, does DMAS allow the school to be an originating site if the individual or family counseling is provided by an LMHP-type?  If the counseling is billed under the TDT service code and not separately as OP therapy, is the use of telemedicine allowed for providing the counseling component of the TDT service? 

Behavioral Therapy Supplement

1.        Pg. 29 – “Providers may accumulate partial hours throughout the week for allowable span billing, however, shall bill only whole hours.”   Should this be Units since BTS is billed in Units, not hours?