Proposed CMHRS Manual Updates -  Goochland Powhatan Community Services Comments:

Thank you for the opportunity to comment.

(1) In Chapter II Pg 9, Adverse Outcomes, it states, “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.”    

Please clarify what the expectations are for tracking consumers who have been discharged in order to complete this reporting requirement.  

(2)   In Chapter IV Pg 9, it states for reimbursement the, “Comprehensive Needs Assessment” must include, “(xv) The dated signature of the LMHP, LMHP-S, LMHP-R, or LMHP-RP”. In Chapter IV Pg 18, it states the, “Case Management assessments require different staff credentials than the staff credentials for direct MH services”. The elements of the “Case Management Assessment” are not defined.  

Please clarify the definitions of “Comprehensive Needs Assessment” and “Case Management Assessment” as well as the elements of and credentials required for each. Please utilize consistent language throughout the manual to reduce confusion. 

(3) In Chapter IV Pg 18, it states, “When the initial comprehensive needs assessment recommends several services for an individual, one assessment will be allowed for all services provided within the same agency.” On Pg 20, it states, “The comprehensive needs assessment must be completed annually for all services or when there is a need based on the medical, psychiatric or behavioral status of the individual.” 

Please clarify whether the annual or additional assessments (after the initial assessment) can be completed with one assessment or whether a separate assessment is needed for each service. 

(4) In Chapter IV Pg 12, it states, “Psychoeducation” means (i) a specific form of education aimed at helping individuals who have mental illness and their family members or caregivers to access clear and concise information about mental illness; (ii) monitoring medication compliance; and, (iii) a way of accessing and learning strategies to deal with mental illness and its effects in order to design effective treatment plans and strategies.    

Please clarify whether a QMHP-Type can conduct Psychoeducation Groups.    

 (5) In Chapter IV Pgs 51-54, the Service Definition for Psychosocial Rehabilitation indicates it includes, “assistance with medication management”.  Further it states, “Assistance with medication management provided by a LMHP, LMHP-R, LMHP-RP, LMHP-S.   A QMHP-A, QMHP-C, QMHP-E or QPPMH under the supervision of a QMHP-A, QMHP-C, QMHP-E, LMHP, LMHP-S, LMHP-R, or LMHP-RP may provide assistance with monitoring medication compliance but must remain within the boundaries of their scope of practice and may not provide assistance with medication management as defined in the definitions section of this chapter”. 

Please clarify what activities are involved in, “assistance with medication management services” that CAN BE provided by a QMHP-A, QMHP-C, or QMHP-E or a QPPMH under the supervision of a QMHP-A, QMHP-C, QMHP-E, LMHP, LMHP-S, LMHP-R, or LMHP-RP.   

(6) In Chapter IV Pgs 54-57 on Crisis Intervention under Service Requirements it states, “An LMHP, LMHP-S, LMHP-R, LMHP-RP, or a Certified Prescreener shall conduct a comprehensive needs assessment as defined earlier in the chapter”. However, it also states, “Provision of short-term clinical care and counseling designed to stabilize the individual or family unit provided by a LMHP, LMHP-R-, LMHP-RP, or LMHP-S” and “Crisis Treatment provided by a LMHP, LMHP-R-, LMHP-RP, or LMHP-S”.  Certified Prescreeners are often not licensed. 

Please clarify whether a Certified Prescreener can also provide crisis treatment or short-term clinical care and counseling.

Thank you in advance for your consideration of these comments when updating these regulations to better meet the needs of all individuals receiving behavioral healthcare services in Virginia