General Comments

Many of the proposed language changes represent significant shifts in policy, credentialing, service delivery, etc. that should be managed through a full regulatory process, not just through revisions to the CMHRS manual, since the manual is designed to be a guidance document.

DBHDS is mentioned and quoted throughout the manual.  Given that DBHDS standards/expectations are mentioned, will DMAS be holding providers accountable to DBHDS standards?  It is very confusing to providers to quote DBHDS standards in the DMAS provider manual as it is perceived to have duplicative accountability and oversight of DBHDS licensure standards.

Please provide clarification throughout manual that MH Case Management services do not require LMHP/LMHP-type to conduct the assessment.  This is not clear in the MH Case Management section of the manual.  Please provide further clarification between the assessment (MH Case Management Services) and the comprehensive needs assessment.

In addition, general questions about the comprehensive needs assessment include:

1. 1. Are providers still allotted the one billable comprehensive needs assessment per year? 
   2. Is the rate going to be the same given that the addendums are allowed within the year? 
   3. Please provide more guidance regarding the addendum as it relates to credentialed professionals who can complete the addendum and if reimbursement will be allowed for each addendum.

There are multiple issues regarding medication management vs. medication monitoring, which can be considered the same intervention in many cases.  There are very few opportunities to provide monitoring of meds without engaging in medication management.  In terms of the flow of service provision, it is not practical to separate the interventions and require different credentials for each, and it is impractical to require licensed staff to perform medication monitoring/management.

Perhaps outside the scope of these comments but worth investigating is what DMAS believes should be the role of the QMHP in the system given that there are so many duties/services/assessments that DMAS seems to believe can only be performed by licensed staff?  If all of these changes were to go into effect, the critical role that QMHPs have played in the system will be greatly diminished and we’ll struggle to be able to provide some of the very services that keep individuals out of more costly, high end services.