In chapter II, they identify a QMHP-Child can only work with individuals under the age of “22years old”.
In chapter IV, they define an “adolescent or child” as someone who is adolescent means an individual 12-20 years of age.
This can cause some problems. One example may be while our youth services folks are used to having a QMHP-A in order to work with young adults, ages 18-21yo, we are completely unprepared for our adult services folks to have to meet the criteria of QMHP-C in order to work with someone 18-22 years old.
Chapter IV in the definitions section, they quote the Code of Virginia’s definition of a QMHP-A, which does not identify any age for that credential.
Magellan of Virginia’s and MCO authorizations form for MHSb says that the cut off is 21 years old.
Chapter IV, page 6, the definition for “Assessment” and on page 9 for “Comprehensive Needs Assessment” only refers to children and adolescents, but not adults.
Ch IV, page 9, the definition for Medication Management describes the activity as “counseling” which is otherwise defined as an activity that can only be done by a LMHP or LMHP E.
In Chapter IV, they took out SSPI and replaced it with “Comprehensive Needs Assessment”—which looks like the same definition. So, does that mean one per agency/provider, or one per service? On page 19—“When the initial comprehensive needs assessment recommends several services for an individual, one assessment will be allowed for all services provided within the same agency. An agency means the same as the DBHDS provider definition located in 12VAC35-105-20. If additional services are required after the completion of the initial comprehensive needs assessment, the provider may amend the initial comprehensive needs assessment or conduct a new comprehensive needs assessment.”
On page 18, the language contradicts this 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
Mental Health Skill-building Services”
On page 34 and 42, in the sections on IIH and TDT respectively: “Prior to admission, a comprehensive needs assessment, as defined earlier in this chapter, shall be conducted by the LMHP, LMHP-S, LMHP-R, or LMHP-RP, documenting the individual's diagnosis and describing how service needs match the level of care criteria. Assessments shall be required at the initiation of services and ISPs shall be required during the entire duration of services.”
So, “as defined earlier in this chapter,” (highlighted above) says that if the initial comprehensive needs assessment identified the need for multiple services, one CA is sufficient, AND that if we identify an additional service after the completion of the initial, we can amend the initial OR conduct a new one… this wording in the IIH and TDT sections seems to contradict that definition on page 19.
Page 23, it refers to the SSPI at the bottom of the page.
Ch IV, page 20: “The comprehensive needs assessment must be completed annually for all services or when there is a need based on the medical, psychiatric or behavioral status of the individual”—this also appears to contradict the statement on page 19. Does this mean one CNA counts for all services annually, or does this mean every service must do a new CNA annually?
MCO authorization form continues to list the SSPI, not the Comprehensive Needs Assessment.
Ch IV, page 26, please provide more clarification about the section on screening for risk of physical injury.
What is meant by an “emergency services assessment,” seeing how it goes on to distinguish that from the requirement to seek a prescreening for inpatient psychiatric treatment. Does this mean an ER visit or Urgent Care visit?
In #2: “Once the individual is referred for community based services the comprehensive needs assessment must be completed by the provider selected by the individual’s caregivers.” Please clarify what is meant by “caregivers” assuming this section is about all ages in CMHR services.
Ch IV, page 49—“continued stay requests longer than 90 days” requires face-to-face assessments. if we do the request less than 90 days, face-to-face is not required?
Ch IV, page 57—under the Crisis Intervention section—it says that CI may be provided in settings other than the outpatient clinic if “clinically/programmatically appropriate based on the needs identified in the comprehensive needs assessment.” For crisis intervention, will the prescreening (if done to determine need for inpatient treatment prior to referal for CI) meet the definition for “comprehensive needs assessment”?
Ch IV, page 58 – ICT provides long term needed treatment, rehabilitation, and support services to identified individuals with severe and persistent mental illness especially those who have severe symptoms that are not effectively remedied by available treatments or who because of reasons related to their mental illness resist or avoid involvement with mental health services in the community. ICT services are offered to outpatients outside of clinic, hospital, or program office settings for individuals who are best served in the community. ICT services include assessment, counseling, assistance with medication management, crisis treatment, and care coordination activities through a designated multidisciplinary team of mental health professionals.
Is it true that only LMHP can provide medication management?
With the clarification on “counseling”—this means that a person in ICT services also has to be in outpatient counseling services? While we do not see this as new language within ICT description, however, the recent clarification of “counseling” in relation to TDT services puts this in new light. If it is truly intended that a person must be in outpatient counseling in order to participate in ICT, this presents a concern and a barrier.
Ch IV, page 59 --Service Requirements for ICT
“Prior to admission, an appropriate comprehensive needs assessment, as defined earlier in this chapter, shall be conducted by the LMHP, LMHP-S, LMHP-R, or LMHP-RP, documenting the individual's diagnosis and describing how service needs match the level of care criteria. Comprehensive needs assessments shall be required at the onset of services.” This statement appears to contradict previous statement that one CNA is required within certain expectations.
Counseling provided by LMHP, LMHP-R, LMHP-RP, LMHP-S. With the clarification on “counseling”—this means that a person in ICT services also has to be in outpatient counseling services? This presents a concern and a possible barrier.
Continuation of Services: ICT may be reauthorized based on a written assessment and certification of need by a LMHP, LMHP-S, LMHP-R, and LMHP-RP that determines if the individual continues to meet the medical necessity criteria. The results of the review must be submitted to receive approval of reimbursement for continued services. Does this mean an authorization will be required?
Ch IV, page 61 – Crisis Stabilization Services: The comprehensive needs assessment must document the need for crisis stabilization services. Previously, it was not required to do a full comprehensive assessment in order to open someone to a crisis service, only a prescreening for admission or similar. This may be a barrier to individuals with urgent needs to get a less restrictive level of care rapidly.
Medication management is provided by licensed staff only. Monitoring by QMHP. Please clarify, who can administer the medication?
Ch IV, page 64 - The provision of this service to an individual shall be registered with DMAS or its contractor within one calendar day of the completion of the comprehensive needs assessment. Individuals are admitted to residential crisis stabilization on Saturdays. Should this be Business or calendar day??
Ch IV, page 66 –states “a comprehensive needs assessment must be completed,” which contradicts initial clarification that only one is required within certain expectations and time frames.
Ch IV, page 78 – “The CM comprehensive needs assessment is part of the first month of CM service and requires no service authorization.” This implies that a comprehensive needs assessment has to be completed at the on-set of the CM service.
Ch VI, page 10 – “All services require a comprehensive needs assessment which is required at the onset of services.” This appears to contradict initial definition. Does it mean that every service is required to complete a CNA?
