Manual

Chapter

Page

Note/Concern

CHMRS

II

8

DMAS MCO contracts require records to be kept for 10 years and this manual indicates that 5 years is appropriate.  The VACSB would prefer the shorter retention period.

9

The VACSB has several concerns with the Adverse Outcomes section.  One concern is related to HIPAA which allows for the sharing of information only by providers who are being paid for service delivery.  If an individual has been discharged from service and the CSB has not been paid for a service for an individual in the past 180 days, then what right does the CSB have to share information on a client?  It is also unrealistic to expect CSBs to keep up with individuals who have been discharged for up to 180 days and report serious incidents, including serious complications from psychotropic meds that result in medical intervention.

12

The definition of LMHP does not include RN's and should.

15

“Payments shall not be permitted to health care entities that either hold provisional DBHDS license or are not credentialed with Magellan of Virginia or Medicaid-contracted MCO prior to rendering that service.”  Please provide clarification on the use and purpose of the provisional license given that providers with this license are not able to be reimbursed for services provided.

15

The psychosocial rehabilitation service should include peer recovery specialists in the list of providers.

16

ICT/PCT teams meet criteria of VAC35-105-1370; however, further down in the proposed changes, there are details about which staff are appropriate to perform which function that appear to differ from the cited regulation.

28

Please define what it means to appeal adverse benefit determinations.  What is the process?  When is it appropriate/allowable to appeal?