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Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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1/15/19  5:31 pm
Commenter: Lisa Snider, Loudoun County MHSADS & VACSB DS Council

Manual Comments/Concerns

These concerns and comments are posted on behalf of both Loudoun County MHSADS and VACSB DS Council.

Appreciative of the work to develop a comprehensive manual for Support Coordination.  One overarching concern is the commitment and responsibility of ensuring the manual remains updated as information is updated.  Who is responsible for updating the information?  Is there an automatic review schedule?  How will the manual be kept up-to-date?

There are instances where the information provided in the manual is confusing and/or contradictory to other information in the manual or guidance previously provided.  Here are the concerns noted related to content:

  • Page 14: Gives an overview of the DOJ settlement ruling, but doesn’t say what, if anything, it has to do with support coordination or give any indication of why it is included in this manual.See comment below related to Page 65.

  • Page 43:The Segway from talking about dignity of risk, confidentiality, etc. into LifeCourse is abrupt.

  • Page 50: Why is support Coordination overview chapter 2? Shouldn’t this be Chapter 1?

  • Page 54: Support Coordination Process overview: I think this would make sense if it were the first thing in the chapter, before the different types of support coordination. I think this would make more sense.

  • Page 56: Goes from recognizing limits in support coordination right into mandated reporting and serious incidents/Human rights abuse, and then into the importance of documentation. Does not flow well.

  • Page 58: Indicates it is the Support Coordinators responsibility to follow up on CHRIS reports from private providers.While we agree, the Support Coordinator is responsible for assuring known risks are addressed (while at the same time understanding an individual’s right to dignity of risk and person centered planning), DHBDS licensing and Human Rights are the receivers of the CHRIS reports.The system is designed for notification to DBHDS of injuries and allegations, not notification to the support coordinator.If the intent is to notify specific support coordinators, the system needs redesign.Further, these should be explanation of DBHDS’ role. Even the way the “case manager reports” are set up in CHRIS present real concerns as noted below:

    • Support Coordinators have to log into the system to find information.With other responsibilities, this is not something that can be done on the daily.

    • The “Case Manager” report can only be run by date range, not by individual.

      • This presents some HIPAA/ethical concerns of every support coordinator in an agency seeing information about those they are not assigned the support coordinator.

      • The report is cumbersome to sort through to find out if there is a report for an individual.

      • For larger CSBs, the resource needed to pull the report, manually divide by individual and then by Case Manager is an unrealistic responsibility.

    • The “Case Manager Reports” do not provide enough information.After all the work of pulling and sorting the report, you are left with the individual name, date of incident and then that it is a serious injury.No other information is provided.

  • Page 65:

    • This addresses the settlement between the USDJ and the commonwealth. It would make more sense to put the overview of the DOJ ruling, from page 14, here rather than where it is currently located.

    • Bullet point 3 says that an individual’s case manager shall meet with the individual face to face every ninety days. It then says the visit must occur at least every 30 days. This wording is confusing.

  • Page 78: Enhanced Case Management Flow chart. This chart is not clear.

  • Page 324:This indicates Support Coordination responsibility to obtain a copy of the MCO HRA and Individual Care Plan.However, it does not indicate who or how the Support Coordinator is to find out who the care coordinator is or who to contact if there are issues with receipt.It also should be clear the MCOs have the responsibility to reach out and collaborate.

  • Page 867:The Assessment section indicates the Annual Risk Assessment is only completed on non-SIS years.This is in contradiction to recent information provided from DHBDS regarding responsibility for completing annually/to have no more than a year apart from last completion.This needs clarity.

The manual lacks information regarding the important considerations and requirements.  Thus, information about the following should be added to the manual. 

  • Based on recent emphasis and audits, add information that Risks Identified in the Annual Risk Assessment must be addressed in PCP or noted why not addressed.

  • Add that if a Risk on a previous Annual Risk Assessment is no longer identified, there must be documentation of why it is no longer a risk. This is based on recent DMAS QMR audits.

  • There is little information about HCBS Waiver and the link to information about compliance efforts.Although this is not a direct Support Coordination responsibility, it is important to have links on where to find more information, etc.

In its current layout provided on the Town hall website, the information presentation is often repetitive and has much information which could be better placed in an appendix.  The manual itself does not begin until page 35.  Below are examples of information that is repetitive or may be better placed in an appendix.  

  • Page 15: Glossary of acronyms. Maybe it would be better to put this in an appendices at the end of the manual?

  • Org Charts, Employee Directory, etc.:Better placed at the end of the manual as an appendix.

  • Page 83: Introduces forms, such as the training center post move monitoring report. Does not flow well. This could be in an appendix.

  • Page 90: this begins the WaMs user guide. Again, this could be a separate document or in an appendix

  • Page 217-220: This is just definitions of different types of developmental disabilities (autism, CP, etc.).This should be an appendix.

  • Page 228: This is a chart of neurodevelopmental disorders. Could be put in an appendices. This is repetitive after just reading definitions of all the different developmental disorders.

  • Page 230: Appears to be a PowerPoint about how consent is obtained. This is directly after several pages on consent, legal guardians, authorized reps, etc. It is repetitive.

  • Page 302: This is a study that was done on supportive decision making. Is this really appropriate for the manual? This could be a link or in an appendices.It also contains several blank pages

  • Page 333: This begins a sample of all the different forms that SC’s are to complete. This could again be in an appendices.

  • Page 338: This is an overview of the use of psychotropic medication for DD individuals. This could be a link to the article. It is also sandwiched in the middle of the samples of forms to be filled out (including the same forms but in Spanish) which is a strangle place to put it.

  • Page 378: This is a Waiver slot committee volunteer application. Again, could be a in an appendix

  • Page 397: This is a SIS user guide; make part of appendix

  • Page 490: This is another PowerPoint on decision making and consent. It is repetitive

  • Page 565: This is the Supportive Decision Making Study, again

  • Page: 654: This is a flow chart on the DDA support team referral process. This has been covered many times in earlier parts of the manual and is repetitive

  • Page 657: This is the WaMS user guide again.

  • Page 657-932 just appears to be a repetition of earlier information including the WaMS user guide, information about the DOJ settlement, and information about enhanced case management that was presented earlier.