Recommendation: Pull the start date for these and convene a workgroup that includes CSBs that provide these services. Our immediate concern is that these increases in services required to be provided by LMHP type providers will prevent /limit NorfolkCSB from being able to bill for PACT and Crisis Stab - the biggest area of our concern.
Comments / Concerns with CMHRS Manual for Norfolk CSB Services – Current or planned
(NCSB does not provided TDT, IIH, Day Tx/Partial, Psychosocial – so those areas are not reviewed)
Definition of LMHP: Several services are limited to services provided by LMHPs – The definition of LMHP does not include RN’s. (Chapter II p. 12)
Provider requirements for Mental Health Service Agencies (starts Chap II p. 15):
Coordination Requirements of CMHRS Providers (Starts Chap IV p. 16):
CMHRS providers are responsible for care coordination activities that includes both behavioral health and medical needs as documented in the ISP. The concern with this is that the MCO’s responsibility to make primary care and outpatient psychiatric provider referrals available to clients receiving CMHRS services the responsibility of the CMHRS provider. This appears to shift this burden of locating providers in the MCO network. (This may not be the intention, but it should be clear that the MCO is actually responsible for assisting the member and case manager in locating providers in their network.) The significant limitations of the established networks for participating psychiatrists and primary care providers is highly problematic and the CMHRS provider does not have the authority to push providers to make appointments available.
Comprehensive Needs Assessment (Starts Chap IV p. 17):
Comprehensive Needs Assessment (CNA) is now required to be repeated annually for ALL services and must be done by a LMHP type. The initial needs assessment (intake) no longer provides ongoing authorization. However, there is a separate case management assessment also required annually. (So, this means all clients in a CMHRS service must undergo a complete CNA annually. This is a significant increase in the number of LMHP-type assessments required). (Note, is there a fee structure for the CNA and does it have to be provided through the assessment unit of the CSB or can it be provided within the service area?)
Crisis Intervention (Starts Chap IV p. 54)
The Comprehensive Needs Assessment is required to be included in the Pre-Screening Document. Does this mean that if not all of the items (except the two waived later in the manual) in the 15 area CNA are available during the crisis assessment it is possible that the service will not be paid? (p. 55-56)
ICT/PACT (Starts Chap IV p, 57)
ICT definition is very limited in the first paragraph, does not mention community integration activities, medication monitoring, vocational services, peer support, skills training. However is does mention requirement to provide “counseling” that is previously defined as a service that is only available through a LMHP-type. PACT consumers may benefit from “Counseling” individual or group, but it is more appropriate to allow that service to be provided by a separate provider as well. It also requires that medication management and counseling be provided in the community – and medication management is restricted to LMHP-type.
Crisis Stabilization (Starts Chap IV p. 61)
Services include: Does not include psychosocial activities or education, peer support, non-clinical (QMHP-Provided) groups, case management activities, medication and symptom classes/groups by RN’s or LPNs, resource groups, etc. This is a one-hour billable service (unless daily rate established by MCO’s) so the approved activities in the Crisis Stab manual may not be billable time. The bullets later indicate “restorative facilitation” as required activity. Services provided by peers are not mentioned and therefore not billable time? This is very confusing and appears to provide a wide area for interpretation where the MCO may not be required to pay for service time.