CMHRS General– Comments close 7/29/18 and website notes manual will be finalized and posted 8/1/18. Does not seem to give time to thoroughly vet comments that potentially have a large impact on care provisions, particularly considering the breadth of proposed changes.
CMHRS Chapter II, pg 12 – suggest including RN under LMHP listing
CMHRS Chapter IV, pg 6 – Suggest adding certified pre-screener to the list of credentialed staff who can conduct a screening. These staff has extensive training and experience as regulated by the state.
CMHRS Chapter IV, page 18,74 – 3rd paragraph references “all” Mental Health Services shall be conducted by a LMHP/LMHP-type. Suggest clarifying MH Case Management service assessments may be conducted by QMHP.
CMHRS Chapter IV pg. 20 – “Comprehensive needs assessment meeting DMAS telemedicine standards is allowed for Psychosocial Rehab, Partial Hospitalization, Intensive Community Treatment, and Crisis Intervention.” Suggest Crisis Stabilization be included since the comprehensive assessment requirements are not any different for that service in comparison to the others listed. In addition, telemedicine is often used in emergency departments as an appropriate tool for emergency psychiatric assessment.
CMHRS Chapter IV, pg 21-22- most of the additions to the ISP seem cumbersome, and do not add considerable value: suggest removing requirement to list individuals and others implementing the plan (this can be many and can change often); remove “must contain a behavioral support or treatment plan” as this is redundant and the purpose of the ISP; remove identification of employees, contractors, etc., responsible as these may not be identified/known at the time of creating the ISP and may change frequently; recovery plan is redundant as its part of the ISP already.
CMHRS Chapter IV, pg 22- Suggest removing “Providers must ensure that all interventions and the settings of the interventions are defined in the Individual Service Plan.” This requirement does not add value, particularly in a setting that needs to be flexible in where they meet clients, and particularly on an annual treatment plan as it may change.
CMHRS Chapter IV, pg 25- suggest adding LPNs to be able to provide medication management
CMHRS Chapter IV, pg 26- Clarify, is this concerning fall risk? Regardless of type of risk screening, why would it need to go to DMAS? Suggest removing requirement. Or if for fall risk, who can complete fall risk requirements, many of these can be done by admin staff.
CMHRS Chapter IV, pg 38-“Family involvement, including family counseling should occur at least weekly.” Suggest adding “as deemed necessary and at the discretion of the provider.”
CMHRS Chapter IV, pg 42- under counseling requirement, suggests adding “counseling requirement is waived parent/child/guardian declines participation.”
CMHRS Chapter IV, pg 43- Suggest removing family meeting/contact weekly requirement, frequency is high, particularly considering counseling requirement. If not removing, change to an “attempt for family/guardian contact as deemed appropriate by the provider.” Contact with family is not always best for the child in some situations.
CMHRS Chapter IV pg 43-suggest removing ISP update between summer and school as 90days is already in practice. Could result in multiple ISPs update in a three month period.
CMHRS Chapter IV pg 50,54,59,61,71- the language around medication management and medication monitoring is confusing. Recommend clarifying the definition, and removing license or other requirements depending on definition. Many people can prompt about medication, provide written information, and provide general information without needing degrees or license.
CMHRS Chapter IV, pg 54, 57, 59, - Crisis Treatment only lists LMHP/LMHP-type. Suggest adding pre-screeners to list as a part of crisis intervention services, certified pre-screeners are often non-licensed staff and have extensive expertise in this area.
CMHRS Chapter IV, pg 57 - types of services provide by PACT teams, suggest adding terms like “psycho-education, coping skills and activities of daily living coaching, and supportive services” to better describe what PACT teams do and can do with QMPS. Would also add nursing services to the list with appropriate credentials. This will help not confuse these terms with “counseling” and who can provide them.
CMHRS Manual, Chapter IV, page 62- Suggest adding as indicated in parentheses: “Psychiatric evaluation including medication evaluation provided by a licensed psychiatrist (or licensed nurse practitioner) and including pharmaceutical assessment and treatment or prescription medication intervention and ongoing care to prevent future crises of a psychiatric nature.” Crisis stabilization services could also be provided by a “licensed Nurse Practitioner” operating within their scope of practice. NPs are often used due to doctor shortages. Many types of Nurse Practitioners, for example some Family Nurse Practitioners, have extensive psychiatric experience.
CMHRS Chapter II, pg 11 and Chapter IV, pg 2- Concerning QMHP definition: Do QMHPs that were grandfathered in on a variance have to remain employed at their current agency to maintain the QMHP status? Or does the QMHP status in this circumstance move with the person if they change providers/agencies? Board references DMAS and DBHDS for answer.