The definition of medication management has been added to the regulations as counseling on the role of prescription medications and their side effects; the importance of compliance and adherence; and monitoring the use and effects of medications. Monitoring medication compliance, side effects, and providing education has historically been provided by a QMHP.In order to continue to support individuals receiving services it is not practical to require a licensed staff to provide this intervention as it does not require advanced clinical knowledge.

In Chapter IV for ICT/PCT teams the proposed changes including who can perform what function on the team does not appear to be consistent with VAC35-105-1370. PACT/ICT is a multidisciplinary team where all team members provide all clinical services with the exception of nursing interventions and psychiatric evaluations.The structure of the team does not allow for specific delineation in what credentialed provider can provide a very specific intervention.This requirement will significantly diminish the effectiveness and efficiency of the team

In Chapter II it indicates that Crisis Intervention Services can be provided by an LMHP/LMHP type or a Certified Prescreener.In Chapter IV it indicates that only a licensed type can complete 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.

Chapter IV, pg 57 indicates Crisis Treatment can only be provided by a LMHP/LMHP-type.This is inconsistent with Chapter II that also includes a Certified Prescreener as one of the provider qualification that can provide Crisis services.