Comments on the DRAFT Provider Manuals

Thank you for the opportunity to provide comment on the Draft Provider Manuals and your consideration of the feedback provided below.

Psychiatric Services Provider Manual

Chapter II, pg. 15, Provider Qualifications for Psychiatric Services – Crossroads Counseling Center opposes the elimination of VA Board-approved Residents and Supervisees from the provider qualifications for outpatient psychiatric service.  Not allowing Residents and Supervisees to provide these needed services will significantly impact providers ability to deliver needed mental health services to Medicaid members.  Additionally, if this change is proposed to be effective as of the revision date of this manual 10/16/17, this is insufficient time for providers to make such a significant change to their Outpatient program staffing plans to ensure the continuity of care for the Medicaid members we serve. It does not appear that DMAS has fully evaluated the impact to its members before proposing such a significant change in service accessibility and delivery.

Chapter IV, pg. 7, 2nd paragraph – The requirements here describe services and documentation produced by unlicensed therapists, yet in Chapter II, unlicensed therapists have been removed from the provider qualifications list.  The discrepancy between the two Chapters needs to be resolved to clearly provide the requirements on whether Residents and Supervisees may provide outpatient psychiatric services.

Chapter IV, pg. 29 – As of July 26, 2017, service authorizations are no longer required for outpatient psychiatric services, as has been written here.  However, the remaining sections continue to refer to the need for service authorizations.  Recommend the entire section be updated to eliminate references to service authorizations, as appropriate.

Chapter IV, pg. 30, Medical Necessity Criteria – the entire section has been retracted, but no replacement information has been provided on the Medical Necessity Criteria for outpatient psychiatric service.

Community Mental Health Rehabilitative Services

Chapter IV, pg. 2-9, Definitions – Need to replace ‘mental health support services’ with ‘mental health skill-building services’ throughout this entire section. 

Chapter IV, pg. 5, Human Services Field – The DBHDS Human Services and Related Fields Approved Degrees/Experience document was last revised June 2017.  Recommend referencing the most recent document in this and other definitions in this section.

Chapter IV, pg. 5, Independent Assessor – Recommend removing definition since no longer applicable to these services.

Chapter IV, pg. 7, Out of Home Placement – Recommend revising definition to eliminate ‘Level A or Level B’, as done throughout this revision.

Chapter IV, pg. 20 – Recommend eliminating requirement to maintain copy of ICA in individual’s file, or rephrase to qualify for those individuals entering services prior to December 1, 2016 only.

Chapter IV, pg. 28 – Recommend eliminating items #4 -#6 which refer to the eliminated VICAP processes.

Chapter IV, pg. 29, Service Limitations, 2nd bullet – Not clear as currently written.  Recommend rephrasing as written on pg. 67, #7 for MHSS (similar requirement).

Chapter IV, pg. 30 – If EPSDT coverage after 26 weeks under the State Plan still applies to IIH service utilization, this paragraph should not be retracted.  If it has changed, a more obvious announcement through a Medicaid Memo would benefit providers who have had to closely monitoring IIH service utilization to ensure appropriate funding sources are requested on service authorizations submitted to Magellan.

Chapter IV, pg. 34 – Recommend removing items #4-7 as they refer to eliminated VICAP processes.

Chapter IV, pg. 61, MHSS – Recommend the service definition be updated to include the entire description as found in 12VAC30-50-226.B.6.

Chapter IV, pg. 61, #2A.(4) – Remove ‘Axis I’.

Chapter IV, pg. 62, #3 – Does this requirement now include individuals who are 21 years of age? Or is this a typographical error since it used to read ‘younger than 21’ (the Magellan SRA for Adolescents also reads “Under 21”)? May have been an oversight in the regulation 12VAC30-226.B.6.c as well.

Chapter IV, pg. 68, Service Units and Maximum Service Limitations – Per Medicaid Memo 6/30/2016, the maximum weekly allowance for MHSS is 10 Units.  Recommend this be included here as well.

Chapter IV, pg. 68, Service Units and Maximum Service Limitations – Will the accumulation of time to reach a billable unit no longer be an acceptable practice for billing MHSS services?