Page

Topic

RRCS Comment

9

Adverse Outcomes – CMHRS Providers must report any knowledge of adverse outcomes for an individual….who have been discharged from services within 180 days of the incident.

We recommend removing this requirement. Providers cannot be expected to be aware of and track adverse outcomes of clients who are no longer receiving services. This requirement puts an unreasonable burden on providers and we will remain out of compliance.

Page

Topic

RRCS Comment

11

Definition –

Medication Management

We are concerned with the use of the word “counseling” in the definition of medication management.  According to the counseling definition, counseling includes treatment planning, assessment, etc.  The type of medication management here describes education and supports that may be provided to help the client take medications as prescribed.  Please consider changing this to “Medication Supports” or “Medication Education and Supports”. 

We also recommend that QMHP level staff be able to provide this support.

26

At Risk Criteria

This section needs revisions and clarifications to include: the definition of “at risk”, what type of assessment tool must be used and what credentials/qualifications are needed

29

PSR  Registrations/Authorizations

This section and Appendix C appear to have differing requirements for Psychosocial Rehabilitative Services. It is unclear whether PSR requires a registration versus authorization.

53

PSR - Social skills training andpsychoeducation activities.

Social skills training" and "Psychosocial educational activities" are core components to the Psychosocial model. To remove them from "allowable activities would be detrimental to the members' development and training to overcome many obstacles that they encounter. This exclusion of social skills training and psychosocial educational activities, contradicts the Service Definition on 51 which says " This service, Psychosocial Rehabilitation, provides education to teach the individual about mental illness........  to enhance social and interpersonal skills ........ "

72

MHSS – “Mental health supervised living providers shall not serve as the MHSS provider”

This change would create an extreme disruption in RRCS MHSS services and program operations. Our MHSS program has successfully aided clients to gain skills and increase their independence. Clients should continue to have a choice of providers in a variety of DBHDS licensed settings.

Is there another way to achieve the same outcome? If not, will there be a transition period allowed for providers to plan and find alternative solutions that would meet this change?

 9 & 75

Mental Health Case Management: Comprehensive Needs Assessment vs. Case Management Assessment

Clarification is needed in the Mental Health Case Management section of this manual regarding the type of assessment needed for this service. Language in this section is not consistent with the comprehensive needs assessment language used earlier in the chapter.

Earlier in Chapter IV it indicates that a comprehensive needs assessment must be completed by a LMHP or LMHP-type qualification. Requiring a LMHP/LMHP type qualification to perform Case Management assessments is a significant change. This would place a burden on providers of MHCM services, since MHCM providers are not required to be licensed.