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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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1/17/19  9:19 pm
Commenter: Michele Elliott, Hanover Community Services

Draft of Supports Coordination Manual comments

Thank you for the work on this manual. Overall, give direction on the way the manual is to be used. It’s assumed this would be a  “handbook” for Support Coordinators and would specify  the main aspects of the job and the regulations we must follow.  This first draft appears to be a very rough draft, fonts and voice change throughout as if written by different authors.  There is too much repetition and the flow of the chapters and information appear to be choppy. There are inserts, and information embedded into the chapters that appear to be in draft forms.  Chapter 2 should be scaled back to only very basic information (similar to the One Page Descriptions of the DD Waiver) and referencing where in the following chapters more in-depth information can be found. 

Support Coordinators occasionally work with individuals in nursing facilities who have OBRA funding a, and at times review and report on PASSR reports.  The manual needs to have a dedicated chapter to what the expectations are in responding to the PASSR reports, the process to request OBRA Funding, how to work with an individual using OBRA Funds and the role/responsibility of the Support Coordinator in working with OBRA.  (Basically we support someone one with OBRA Funds as if they are SPO but receive the funds up front, the SC assists in securing the recommended service i.e. day support and transportation and works with the provider to set up billing for the funding…..) List of comments:

Page 14:  The overview of DOJ settlement doesn’t explain the “settlement”.  Too vague.

Page 15 and 16:  Inconsistent formatting.  

Page 18:  Chart is difficult to interpret

Page 19-24:  For all the contacts need to have consistent usage of punctuation. 

Page 19-24:  It would be helpful to have an explanation.  For example, “Contact CRC when…..” in a very small font at the top of page 19 would be helpful.

Page 26-28:  Instead of listing every county,  insert a map with the areas color coated 

Housing contact information  is repeated later.

Page 38:  “Issues of safety…”  bullet covers a lot of information, break it down into sub-categories. 

Page 38- 42:  values/practices defined are basic to the field of human services/social work.  Topics seem like common sense in this field and need no further clarification

Page 39: the suggestions for learning about cultures sounds insulting.

Page 43:   using everyday language seems like common sense. 

Page 44:  The link will be helpful!

Page 44:  The length of the “community” definition excessive. 

Page 50:   “billed activities” should be defined here.

Page 52:  Section Targeted Case Management is confusing.  Need to add a  flow chart.

Page 52: Mental Health and Substance Abuse Section – include a sentence in each section referring   to  agency’s guidelines about primary service provider.

Page 53 ECM Criteria  last paragraph of who it applies to contradicts page 53 second paragraph of who ECM applies to.

Page 53: Post Move Monitoring – need directory for the contacts of PMM staff. 

Page 54: Choice of Support Coordinator- include  more information per Emergency Regs regarding the Regional Contract for private contracted case management. 

Page 56: Monitoring/Evaluating – discusses that periodic site and home visits are conducted- include language “ announced and unannounced site and home visits”..

Page 56: Transitions/Transfers – Include a reference to the  finalized Transfer Protocols

Page 57:  Mandated reporting info. Repetitive

Page 57: Require Mandated reporter training. Specify how to access, how often staff need to take the training etc.  Add APS/CPS Hotline

Page 57: DARS and APS- Include DARS role in APS cases

Page 59: Add the SC should be treated with dignity, respect, free from abuse. 

Page 60: Documentation – specify importance of documentation. Refer to chapter 7 for detailed information.

Page 60: Documentation should have  own chapter with timelines.  Reference importance of documentation, records management, refer  reader to agency policy/procedures. Reference  use of EHRs and its interacts with WaMS. 

Page 64: CM  Operational Guidelines- no introduction to section,  Include a finalized copy.

Page 83: PMM Report – out of place add to  PMM section or  appendix   

Page 90:  Remove WaMS user guide.  Add link ore Resource Appendix

Remove blank pages 303, 305, 307, 312 and 313, change font on page 311 push to another page,  reduce pages.

Decision making PowerPoint is repeated.  Information needs to be presented by a qualified professional, remove, offer webinar and insert link to  webinar. Add presentation to appendix.

Manual has too many hyperlinks. Manual should be a quick reference for staff. Hyperlinks can break and information gets updated. All resource information should be put into Appendices for easy replacement when updated.

Page 218:  ID originates before age 18? Or 21?

Down Syndrome  makes it sound like the majority have Down Syndrome.

Page 221:  Information about medications affecting communication and removing meds. Concernings statement, could be misinterpreted and encourage someone to stop taking medications. 

The author of this chapter should provide their name and qualifications.

Expressive and receptive communication is repeated  on page 221,

Page 222: communication tips good information.

Page 223: Role of Family, Legal Guardian, etc. this section out of place, Page 223 -227 and then page 228 is a list of diagnosis.. In the Substitute Decision Making section –there is confusion about ARs.  When transitioning from training centers, is a new AR  required or  another determination process? Include process?  

Page 223, family and friends.  clarify consent is needed for talk to parent of adult child.

Information about guardianship and substitute decision put in one place, refer back throughout the manual don’t repeat

Repeats information in chapter 1. Combine this information with an introduction or overview of PCT. 

Information is too basic, include statement from an individual or advocacy group on what  is important or how individuals want to be treated. 

Information is repetitive of required online training for new SCs.  Delete section,require the online version.

Page 322 states “Developmental Disability Coordination”  Define term, use consistent terms.

Page 322:  Eligibility for Part C Support Coordination:   Not all CSBs/BHAs provide this program. 

Page 322:  Diagnostic Eligibility, be clear; functional eligibility for intake and  VIDES are two different things.  

Page 323:  DD and TCM  Some CSBs provide non billable case management to  DD population who don’t qualify for DD Waiver waitlist. 

Page 324: The Emergency Regs don’t state need for  Annual Risk Assessment/Fall Risk Assessment for  waiver waitlist. 

Page 324:  References collaboration with  MCO Care Coordinator, obtaining HRA and migrating risks, clarify roles.  Doesn’t occur at the MCO level for everyone...   

Page 325: 2nd paragraph states “…can’t be awarded a CL or IS Waiver…” Should Say  FIS Waiver

Page 325: 3rd paragraph states  “For the BI waiver, … if no one in a lower priority category has requested independent living.” Should this say “a higher priority category”?

Page 325:  Clarify that DBHDS is sending the Choice of Waiver forms annually, not support coordinator. 

Page 325: DBHDS sends  “Needed Services” Form  with  Recipient Choice Form- include information on  this form, how often it’s updated,  is it only a DBHDS form, what is  responsibility of  SC?

Page 325:  False statement under waitlist:   “everyone who requests DD Waiver services is added to the waitlist”. Not everyone who requests is found to be eligible.

Page 325: No mention of the 30  day requirement to be on wait list if offered slot. 

Page 325: Include information about Facility Slots, qualifications and  how to obtain one. 

Page 328:  Emergency slot request, reviews decreases in needs with waiver change, but does not review an increase in need (FIS to CL or  BI to FIS)

Page 328: Review/Update VIDES- add  timeline, updated within 6 months of enrollment into waiver per emergency regs.

Page 329, physical exam  needed within 12 months of receiving a waiver,  add  when medical needs change.  Simplify 

Page 329: Choice Protocol- add  for Support Coordinators including Regional Contracted Case Managers

Page 331: Retaining Slots – Requirement for SC send a DMAS 225 to DSS notifying  of no waiver service within 30 days? Include information here and in DMAS 225s section. 

Page 332, nice visual but  not all Individuals are eligible for Medicaid; therefore not all Individuals can receive SPO.

Page332: Separate ID and DD individuals and SPO services- billing and  services are confusing.  Need more information  about what specialized services are, billing difference, etc.

Pages 338-342  remove; present in a training by a qualified physician. Include what a support coordinator needs to know and when to refer to physician

Pages 349-365 should be condensed with  information in Chapter 6. List waiver services with  description once. 

Provide  list of documents with hyperlink in  appendix instead of attaching forms.

Page 391: Request for Emergency Slot and referral to RST – clarify process as per Emergency Regs   

Pages 397-441 the SIS User guide, don’t attach, add link. 

Based on recent ASCEND webinars, need updated manual. 

Description of waiver services repeated.  Include in this chapter and remove all other sections. (remove 349-365 )

Intro is choppy, hard to follow.  Include all waivers for SC  for resources (Tech Waiver, EDCD, etc) add eligibility and how to access

Section on Waivers seems out of place, add to  Intro Chapter 1.

History of Waiver- remove

Clarify introduction, clarify differences between CCC+ and DD.

Description of Waiver Services – include eligibility information here or refer  SC to section of manual.

Resmove blank pages

Page 442: DMAS 225- Annual DMAS 225 for those on Waiver, not in emergency regs.  

Page 449-450:  services under the waiver move to appendix

Waiver Services – Clarify use of waiver with EPSDT services.