59 ICT

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.

59

The 4th bullet:  Requiring that a delineation between medication management and medication monitoring poses challenges.  Due to the shared caseload model and multidisciplinary model used for ICT services, it is impossible to use separate credentialed staff for medication monitoring (QMHP) and medication management (LMHP).  This will significantly diminish the effectiveness and efficiency of the ICT service.  In addition, this seems to exclude nurses and doctors from providing medication management

60

With regard to Continuation of ICT Services:  “The results of the review must be submitted to receive approval of reimbursement for continued services.”  Please clarify as there is no review that is currently required.  Currently, the only “review” that is required is the Quarterly Review.

61 Crisis Stab

Assistance with Medication Management must be performed by LMHP/LMHP-type professionals according to language on this page.  Based on the definition, this is not an advanced clinical intervention therefore not clear on why licensed staff must perform this function/intervention.  CSU does not have enough licensed staff to be the sole staff to provide this intervention.

61

“The goal of this service is to stabilize acute mental health needs at the earliest possible time to avert hospitalizations however counseling has been added as a requirement for this service.”  Counseling is contraindicated for an individual experiencing a crisis.  Crisis stabilization services are very short term which are solely focused on resolving the crisis and connecting to ongoing community-based services.  Additionally, counseling requires LMHP/LMHP-type.  Many CSUs have a limited number of LMHP/LMHP-types in their program.  THIS IS PROBLEMATIC AS CSBs USE THIS SERVICE AS DIVERSION FROM HOSPITALIZATIONS AND STATE HOSPITAL ADMISSIONS.

62

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.

62

With regard to the 2nd bullet:  “Psychiatric evaluation including medication evaluation provided by a licensed psychiatrist and including pharmaceutical assessment and treatment or prescription medication intervention and ongoing care to prevent future crises of a psychiatric nature.”  This is different language than current manual where the evaluation is optional.  Is this no longer optional?  Also, requiring that the evaluation be conducted by a licensed psychiatrist rules out other clinicians who have the appropriate skills to perform the tasks listed.

63

Medication Management excludes medical staff

64 MHSS

With regard to Service Requirements:  Services that continue beyond six months must have a “review” completed by LMHP/LMHP-type.  Please provide clarification on what the review consists of.  Also, how does the “review” differentiate from the Comprehensive Needs Assessment in this case?

68

Language on this page appears to contradict other language throughout the manual which indicates a QMHP can do medication management under LMHP type supervision.

71

Assistance with Medication Management does not require advanced clinical knowledge or skills.  Please consider removing the requirement that this intervention be performed by LMHP/LMHP-type.

71

Disallowing MHSS services to be provided by same service provider as an individual’s MH supervised living or therapeutic group home provider is arbitrary.  Where a person lives should not limit his/her choice of providers.

72

Concern about partnership definition regarding services in Supervised

74

Either remove comprehensive needs assessment from the entire Mental Health Case Management services section OR clarify that MH Case Management services assessment does not require a licensed professional to complete it.

CMHRS

V

1

Please consider standardizing authorization forms and processes for notification of approvals/denials across all of the MCOs

VI

10

Case Management services do not require a licensed individual to conduct the assessment.

Documentation Reqs.

14

The 7th bullet states, “For services where group counseling is allowed, reimbursement is not allowed for more than 10 individuals regardless of Medicaid eligibility”.  Some CSBs provide group counseling up to 12 individuals, which is supported by best practice.  Some providers will not be allowed reimbursement for two individuals if there is a group of 12.

16

The 2nd bullet indicates all progress notes shall be individualized and child-specific.  This should be adult-specific.