|
CMHRS |
II |
9 |
In regards to the adverse outcomes section it would be difficult to track and report the adverse outcomes for someone 180 days post discharge. |
|
|
|
12 |
The definition of LMHP does not include RN's. |
|
|
|
15 |
The psychosocial rehabilitation service should include peer recovery specialists in the list of providers. |
|
28 |
Please define what it means to appeal adverse benefit determinations. What is the process? When is it appropriate/allowable to appeal? |
General Comments
Please provide clarification throughout manual that MH Case Management services do not require LMHP/LMHP-type to conduct the assessment. This is not clear in the MH Case Management section of the manual. Please provide further clarification between the assessment (MH Case Management Services) and the comprehensive needs assessment.
New language added in several areas of the Psychiatric Manual seem to come from the MH clinic manual and would be new practices and in some cases difficult to implement in our current system such as Physician directed language and Prescriber to “prescribe therapy”.
In attempts to coordinate with DBHDS regulations, references to the DBHDS licensing requirements suggests these areas will be reviewed by DMAS, please explain the role of DMAS in overseeing DBHDS regulations.