Entered on behalf of both the VB Dept. of Human Services and the Region 5 CSB Quality Leadership committee.  We respectfully request consideration of the following issues during the upcoming review and revision of 12VAC35-105:

1. A general effort to ensure Licensing expectations are consistent with those of other regulatory bodies with oversight responsibilities for providers of Behavioral Health and Developmental Services (e.g. DMAS, DOH, other offices within DBHDS).  Suggestions include:

• Ensure clinical documentation requirements are consistent and streamlined with those of other oversight bodies.

• Clarify that for a provider of multiple services, a single intake assessment is valid for a specified time period (e.g. six months), with updates to confirm the individual meets the eligibility criteria for referral or transfer to another service offered by the provider, vs. requiring the individual to sit through a complete assessment of historical information when the information has been gathered by the provider.

2. Opportunities to streamline processes in terms of issuing licenses.  Suggestions include:

• Reduce the number of licenses for DD/ID day support to two, based on age range.Program descriptions articulate the specifics of programing (e.g. group day, community engagement, and/or community coaching) and populations served (e.g. DD with ID, DD without ID.

• Reduce the number of program types where separate licenses are issued for mental health and substance abuse services in light of the known overlap of these diagnoses among individuals in need of behavioral health services.Program descriptions articulate the specific population served, as well as inclusion and exclusion criteria.

3. Revisions to the language regarding reporting requirements in the area of serious injury reporting.  Suggestions include:

• Clarification of language and expectations with a shift from “Serious Injury” to “Serious Medical Event”.

• Clarify expectations to focus on events that occur during face-to-face service provision or when individuals are under the direct supervision of staff of a licensed provider and which, as a result, involve service provision by employees of agencies licensed by DBHDS.

• Revise language to require reporting of Serious Medical Events within 24 hours or on the next business after weekends and holidays.There would be no detrimental effect to individuals receiving services by this change, nor are DBHDS staff members expected to act on this information during weekends and holidays.