CMHRS

IV

6 and 7

The difference between assessment and comprehensive needs assessment is not clear as  defined on page 6 and 7.

6

Please add certified pre-screener to the list of credentialed staff who can conduct a screening. 

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 and 16

Magellan of Virginia provides care coordination to individuals enrolled in FFS and Medallion 3.0 through Care Management staff. P. 15   and  CMHRS providers are responsible for care coordination activities that includes both behavioral health and medical needs as documented in the ISP. (p. 16).  How are both of these statements true? 

16

What is the role/expectation of care coordination for secondary services (such as PSR, MHSS) within a CSB that also provides case management?

18

Service-Specific Provider Intakes Comprehensive Needs Assessment for all Mental Health Services shall be conducted by a licensed mental health professional (LMHP, LMHP-S, LMHP-R or LMHP-RP. (p. 18)  This is not true for CM?

18

On page 18 it indicates that an ISP should include  a recovery plan, if applicable.  When would this be applicable?

19 and 20

What are the qualifications for someone updating or amending the assessment? Does it have to be a licensed staff?

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.

22

Providers must ensure that all interventions and the settings of the interventions are defined in the Individual Service Plan. (p. 22)  How would setting be defined?  For ICT for example, interventions are often provided in multiple locations—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

Professional c Clinical services including assessment, crisis treatment, counseling and assistance with medication management, ,must be provided by a LMHP, LMHP-R, LMHP-RP or an LMHP-S (p. 25).

Would an LPN be able to provide medication management?  Counseling is a required activity in ICT, though ICT staff are not required to be a licensed type. 

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

The requirements regarding the At Risk of Physical Injury screening (p. 26) and use of the DMAS-P502 are confusing.  At times it appears that this requirement only applies to kids—at other times it appears to all Medicaid members receiving any of the CMHRS Services.  Also not clear if the DMAS-P502 is required or optional.

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. 

Psychosocial Section

51

These services include assessment, assistance with medication management, restorative facilitation and care coordination (p. 51).  Earlier in chapter it indicates that assessment and assistance with medication management can only be provided by licensed type staff.  Does this mean that we have to employ licensed type staff in PSR? 

54 PSR

Assistance with “Medication Management” is identified under covered services.  This is a typical and traditional intervention provided under psychosocial rehab services.  Please exclude the requirement that this be performed by an LMHP/LMHP-type. 

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.

Crisis Intervention Section

54 Crisis/Emer.

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

57

Crisis intervention activities shall include assessment, short-term counseling designed to stabilize the individual, crisis treatment, and care coordination. Earlier in the chapter it indicates that counseling and assessment have to be provided by a licensed type.  Does this mean a QMHP who is a certified pre-screener cannot provide crisis intervention?  Chapter 2 (p. 16) includes a pre-screener as someone who can provide crisis intervention.

Finally, please allow the preadmission screening to serve as the Comprehensive Needs Assessment in this setting.

ICT

Can an individual receive Case Management, ICT and MHSS all at the same time? 

57

In ICT section ICT services are offered to outpatients outside of clinic, hospital, or program office settings for individuals who are best served in the community.(p. 57)  There must be typos in this sentence.

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

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). Does this mean that ICT teams have to be staffed with licensed type professionals?  

 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.

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.

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?

66

Comprehensive needs assessment shall be repeated upon any lapse in services of more than 30 calendar days. Please define lapse of service.

67

Providers may bill for service hours or bill for the comprehensive needs assessment to complete the six month MHSS review requirement.  – Can it be a comprehensive update/review of the plan and assessment at six months for billing or does there needs to be another SSPI/Comprehensive needs assessment to bill?

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.

70

Support activities and activities directly related to assisting an individual to cope with a mental illness to the degree necessary to develop appropriate behaviors for operating in an overall work environment shall be billable. However, any services provided to individuals that are strictly vocational in nature shall not be billable. clarification is needed on what is considered support activities. Would this include job club group where the members learn about symptom management, communication skills, appropriate hygiene, etc., to help them develop appropriate behaviors when in the work place?

Mental Health Case Management

74

Care Coordination is defined as locating and coordinating services across multiple providers to include collaborating and sharing of information among health care providers, who are involved with the individual’s health care, to improve the restorative care and align service plans. The list of required activities for case management include:

• Assisting the individual directly for the purpose of locating, developing or obtaining needed services and resources;
• Coordinating services and treatment service planning with other agencies and providers involved with the individual.
• Following up and monitoring to assess ongoing progress and ensuring services are delivered.

These seem duplicative.  Also, if it is the role of the Care Coordinator to collaborate and share information among providers, why is it required that we coordinated with Primary Care Provider?

CMHRS

VI

10

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