The shift to allow for a single Comprehensive Needs Assessment (CNA) per provider vs. the requirement for multiple Service Specific Provider Intakes from a provider offering several services to the same individual is appreciated, as it streamlines the process for individuals accessing services.  However, the requirement that allows the CNA to be valid for only 30 days prior to the initiation of MHSS is counterintuitive in light of MHSS’s focus on individuals with needs for supports in areas of slow change, versus shorter term or crisis focused services.

Also appreciated are the efforts to efforts to streamline and increase consistency across various DMAS requirements and with the DBHDS Office of Licensing.  Please consider continued improvements in the timing of quarterly progress reviews, setting the due date for these reviews to occur at the end of each quarter, vs. 90 days.  This increases consistency with Licensing (12VAC35-105-675) and with existing DMAS requirements for ID/DD services, while having no impact of clinical significance for individuals receiving CMHR Services.  Enhanced uniformity is conducive to enhanced compliance and improved service delivery.

Concerns regarding the new expectations decreasing QMHP’s ability to provide crisis intervention activities have been raised by other providers and we share these as well, in particular with regards to ICT/PACT’s interdisciplinary team services.  In light of the nature of the service, the required make-up of the team, and the individuals served, any staff member on the team needs to be skilled in de-escalation and crisis intervention.  As now written, it is conceivable that a QMHP-A level staff member could arrive at the home of an individual, find the individual in crisis, and be required to delay care by contacting and awaiting the arrival of a LMHP/LMHP-type.  Under the new Board of Health Professions regulations, QMHP-A staff members have been assessed and determined to be capable of doing the tasks of their work, including recognizing when consultation with a staff members with greater clinical training is indicated.  As others have indicated, the required composition of ICT and PACT teams does not set the stage for a greater number of LMHP/LMHP-types. 

Regarding Chapter VI, page 8 – was it the intent to delete the recognition that ICT/PACT services may provide case management?  If that is the case, please be aware that providers of ICT/PACT will run the risk of being out of compliance with DBHDS Licensure requirements, as articulated in 12VAC105-1410.2, which clearly states that the service requirements include Case Management.

The increased reliance on individuals who are licensed or under supervision to become licensed has long-term implications for the ability of supervisees/residents to gain adequate training to become independent practitioners and has the potential to result in decreased ability to meet the needs of individuals with mental health issues throughout Virginia, as this is a limited resource.