26

This section needs significant revision.  In particular, what screening is this referring to?  Is this for all CMHRS services?  Does “At-Risk of Physical Injury” refer to self-injurious behavior, fall risks, etc.?  This section also states that the “screening” needs to be performed by a LMHP/LMHP-type which seems unnecessary.  Also, please add certified prescreener to the credential that is accepted. 

26

Under #2, it indicates that 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 or define caregivers, assuming this section applies to all age groups.

26

Under #4, please clarify how the risk screening will be submitted to DMAS.  How will the provider be notified if the screening has been approved?  Is the DMAS-P502 optional or required?

29

We remain concerned that all MCOs can require different registration/authorization process but the 2nd paragraph refers to Appendix C for additional information on what services require authorization versus registrations. In Appendix C, there is a strike-through Psychosocial Rehabilitative Services under authorizations.  Does this mean that registrations will be permitted for PSR services?

38

“Family involvement, including family counseling,…should occur at least weekly.”  This sentence contradicts previous statements from DMAS indicating that the frequencies of individual, group and family counseling is at the sole discretion of the provider.  Please clarify.

42

3rd bullet under Service Requirements:  What happens if a child or parent is interested and needs TDT services but declines counseling?  Please clarify.

43

With regard to family meetings, family counseling is required and weekly family meetings are required.  Is the expectation that these sessions be separate given that the frequency of family counseling is at the sole discretion of the licensed professional?

43

Under additional covered services:  Are these services mandated or optional and reimbursable if provided?  The language says what providers “must” do however it’s listed under covered services, not required services.

47

This page references the DBHDS Office of Licensing service differentiations.  Is DMAS holding providers accountable to DBHDS standards/expectations?  Mentioning DBHDS standards/expectations throughout this manual is confusing to providers as it pertains to oversight and accountability. 

50

Assistance with “medication management” has traditionally consisted of education and support.  This is not an advanced clinical practice therefore please exclude the requirement that this be performed by licensed staff.

54 PSR

Assistance with “Medication Management” is identified under covered services.  This is a typical and traditional intervention provided under psychosocial rehab services.  This intervention does not require advanced clinical knowledge.  Please exclude the requirement that this be performed by an LMHP/LMHP-type.  There aren’t enough licensed staff to perform these functions nor is it necessary that it be provided by this advanced credentialed professional.

54

Medication Monitoring is permitted by a QMHP however Medication Management is only permitted by LMHP/LMHP-type.  There are very few times and opportunities where a professional will monitor medication compliance and not provide some level of education and support.  There is huge overlap between monitoring and management.  This credential requirement for medication management should be reconsidered.  Both interventions go hand-in-hand.

54 Crisis/Emer.

Crisis Treatment only lists LMHP/LMHP-type.  As a part of crisis intervention services, certified prescreeners are often non-licensed staff.  Please add this credential to this definition.

57

The 4th bullet indicates that:  “Short-term clinical care and counseling designed to stabilize the individual or family unit provided by LMHP, LMHP-R….” is now under required services instead of covered services.  It is impossible for licensed staff to provide counseling in all settings with all recipients who receive crisis intervention services.  Counseling is not appropriate for an individual who is in the midst of a crisis, psychotic, suicidal/homicidal, etc. Additionally, certified prescreeners are not all licensed staff and would not be able to perform this intervention if this remains.  Please remove or reconsider.  Crisis Treatment should be removed from Required Services or please add certified prescreener to list of accepted credentialed providers.  Finally, please allow the preadmission screening to serve as the Comprehensive Needs Assessment in this setting.

57

Under Services Definition:  There is a typo on line 6.  Should it be “patients” or “individuals” instead of “outpatients”?

57

Adding Counseling, which by definition requires provision by LMHP/LMHP-type, is problematic as many staff on ICT teams are not licensed or licensed eligible.  Mostly QMHPs provide this service. Also, depending on the population served for the particular team, some individuals (severe psychosis) may not be appropriate for therapy/counseling however they often receive supportive counseling and problem-solving interventions.

57

The credentials for professionals who can provide the ICT service (QMHP, etc.) contradict your requirements of LMHP/LMHP-type to provide crisis treatment.  PACT/ICT is a multidisciplinary team where all staff (QMHPs, RNs, LMHP/LMHP-types) provide all clinical services with the exception of nursing interventions and psychiatric evaluations.  The structure of the team does not allow for hard lines in what credentialed provider can provide a very specific intervention.  This requirement will significantly diminish the effectiveness and efficiency of the team.  Please remove or reconsider.

57

ICT services include assessment, counseling, assistance with medication management, crisis treatment, and care coordination activities through a designated multidisciplinary team of mental health professionals. Four of the five interventions listed require licensed/licensed-eligible staff (under new draft definitions).  Please remove or reconsider the requirement for LMHP/LMHP-type staff to provide these interventions.

58

Under Service Requirements, the 1st bullet states, “Prior to admission, the Comprehensive Needs Assessment shall be conducted…”  This is inconsistent throughout the manual.  Please provide clarification if the assessment is completed AT the initiation of services or PRIOR to admission.