CMHRS

IV

1

Please consider standardization of authorization forms and processes for notifications of approvals or denials.

6

Adults are not included in the definition of assessment.

6

Please add certified prescreener to the list of credentialed staff who can conduct a screening.  Not all certified prescreeners are LMHP/LMHP-type and requiring such would negatively impact the ability of CSBs to comply with their code mandated responsibilities.  The VACSB can provide information about the extensive certification, general and on-board training required for individuals to become prescreening clinicians.

6

Please add adult to the definition of Comprehensive Needs Assessment; only children are referenced. 

6

The definition of counseling states that the principles of the Counseling Profession must be applied however what if the professional is a social worker, clinical nurse specialist, NP or psychologist?  The definition is very narrow and disregards the principles, standards and methods of other professions.

6

Based on the definition, it appears as if crisis treatment will be a part of crisis intervention.  The VACSB does not support this shift in policy.  If DMAS insists on moving forward with this policy shift, then please add certified prescreener to the list of credentialed professionals who can provide this intervention.   It will limit the scope and capacity of the services for which crisis treatment is embedded.  Also, the phrase “immediate access” is ambiguous.  Please either define it practically or use more precise terminology.

6

The use of the word counseling in the definition of medication management is misleading.  According to the counseling definition, counseling includes treatment planning, assessment, etc.  The medication management here describes education and supports that may be provided in order to assist the individual with adhering to prescribed medications.  Please consider changing this to “Medication Supports” or “Medication Education and Supports”.  Lastly, this is an intervention that does not require advanced clinical knowledge, therefore it should not be required to be provided by LMHP/LMHP-type.

6

Regarding the definition of QMHP-A and QMHP-C, some CSBs have transition-aged youth programs and have QMHP-As providing the services for individuals ages 16-25.  This definition is problematic for providers as it indicates that only QMHP-C can provide services to individuals under the age of 22.  The definition in the Virginia Code does not identify an age. Please consider removing this provision.

9

Please exclude mental health case management from the definition.

9

The counseling definition is limited to licensed individuals.  Many of the educational and supportive counseling services are appropriately delivered by QMHPs at present.  The multiple changes to this practice as proposed in this manual will create additional workforce challenges.

15

With regard to care coordination, please provide clarification and indicate how both statements apply given the duplicate roles indicated here.  The manual states, “Magellan of Virginia provides care coordination to individuals enrolled in FFS and Medallion 3.0 through Care Management staff.” Page 16, states, “CMHRS providers are responsible for care coordination activities that includes both behavioral health and medical needs as documented in the ISP.”

18

Modify the 3rd paragraph which states that ALL Mental Health Services shall be conducted by a LMHP/LMHP-type.  Please qualify and indicate that MH Case Management service assessments may be conducted by QMHP.

19

Add that the Comprehensive Needs Assessment is valid for one year/12 months/365 days or sooner as needs change.  In addition, this language contradicts statements in the IIH and TDT sections which state the Comprehensive Needs Assessments shall be required AT the initiation of services.  This indicates that it is required PRIOR to initiation of services.  Please provide clarification.

20

The VACSB suggest clarifying that the prescreening evaluation can suffice for the Comprehensive Needs Assessment for Crisis Intervention services at CSBs.

21

A crisis plan, relapse plan and recovery plan can be one in the same.  Please clarify if they are intended to be different OR provide definitions for each and clarify when the crisis plan, relapse plan and/or recovery plan would be applicable.

21

Given turnover and leave scheduling, it would be difficult to provide actual employee names of those who may be responsible for service coordination and integration of services on the ISP.

22

The code indicates that a guardian cannot be required to sign the ISP or the Quarterly Review if an individual is seeking outpatient services.

22

“Providers must ensure that all interventions and the settings of the interventions are defined in the Individual Service Plan.”  How would setting be defined for mobile services?  For example, ICT interventions are often provided in multiple locations depending on where the individual is - we may be providing nutritional support at the grocery store, in the client’s residence, at the library looking at recipes, etc.  Would “community” be an adequate description of the setting?

25

Indicates all Clinical Services including assessment, crisis treatment, counseling and assistance with Medication management be provided by LMHP.  The 2nd bullet needs clarification regarding what clinical services are being referred to.  Assessment for MH Case Management services does not require LMHP/LMHP-type, how do peer recovery specialists fit in, and Medication Management does not require advanced clinical knowledge based on definition therefore please remove the LMHP/LMHP-type from the credential requirements.  The definition as described also excludes LPNs from providing medication management.