The requirement that CMHRS providers must report any knowledge of adverse outcomes for an individual currently receiving services or who have been discharged from services within 180 days of the incident, It is 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.
Chapt IV
Page 6- Please add certified prescreener to the list of credentialed staff who can conduct a screening. Not all certified prescreeners are LMHP/LMHP-type and requiring such would negatively impact the ability of CSBs to comply with their code mandated responsibilities. The VACSB can provide information about the extensive certification, general and on-board training required for individuals to become prescreening clinicians.
TDT Family involvement, including family counseling and contacts from the beginning of treatment is extremely important and, unless contraindicated- impossible task due to family schedules and resistance. Schools do not have private space for family sessions nor is it safe for staff to stay after school staff have left which may be the only time families can come in. Not clear and unrealistic.
PACT Under 16 (2), I would more strongly state that we do not believe that such classes of professionals can provide “assistance with medication management” as it is defined, as the definition appears to require medical training such as is available on to an RN or MD. Ie: it is by definition outside the boundaries of their scope of practice Adding Counseling to PACT, 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.
The credentials for professionals who can provide the ICT service (QMHP, etc.) contradict your requirements of LMHP/LMHP-type to provide crisis treatment. PACT/ICT is a multidisciplinary team where all staff (QMHPs, RNs, LMHP/LMHP-types) provide all clinical services with the exception of nursing interventions and psychiatric evaluations. The structure of the team does not allow for hard lines in what credentialed provider can provide a very specific intervention. This requirement will significantly diminish the effectiveness and efficiency of the team. Please remove or reconsider.
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). Please remove or reconsider the requirement for LMHP/LMHP-type staff to provide these interventions.
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
