Psych Svcs

IV

32, 33

The physician-directed language has been added to this manual.  This would be very difficult to implement as CSBs already have difficulty having sufficient prescribers to manage client needs.  This language is also limiting in that it specifies physician, which means that neither an NP nor a PA could be used for this purpose, despite the fact that arrangement is perfectly acceptable one in other areas of practice. 

Psych Svcs

II

The VACSB has several concerns with the notification of adverse events requirement.  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.

Psych Svcs

IV

36

Language on this page “The initial Plan of Care must be completed prior to the start of services.”   From a recovery and person-centered perspective, this is impossible.  The development of the Plan of Care is a collaborative process with the client and is initiated during the first service.  Is development of the Plan of Care billable?

37

Please define compliant with treatment.

40

How is proficiency defined?

Psych Svcs

VI

10

Language on this page states that all services require a comprehensive needs assessment and that it must be completed face to face by an LMHP, LMHP-S, LMHP-R, or LMHP-RP.” This contradicts Chapter 4 in the CMHRS provider manual which indicates that Case Management services assessment can be conducted by QMHPs.  Please add clarification.