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Virginia Regulatory Town Hall
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Department of Behavioral Health and Developmental Services
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State Board of Behavioral Health and Developmental Services
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1/17/19  9:23 pm
Commenter: Michele Elliott, Hanover Community Services Board

Additional Comments to Draft of SC Manual
 

Clarify Time Limited Services  ex. Community Coaching can’t be ongoing-state this in the description.

Page 459: In Home Supports- clarify what portion of  service has to be provided in the home. 

Page 463: include information regarding family as sponsored residential provider.

Page 466, clarify difference ins waiver that offers alternative services to people on the waitlist.  Add inability to have both,  Add  section about transitioning between CCC+ waiver and DD Waiver.

Page 467-cover MCOs one time in the manual, don’t repeat.  Information sounds like  SC will only work with  MCO when  Individual has CCC+ Waiver.  An Individual on the CCC+ waiver may/may not qualify for DD  Waitlist.    

Page 468:  Add Mental Health Supports

Remove power point on Substitute Decision Making.  Offer training on this, provide  information there. 

Repetitive information

Reference Person Centered Practices, inform SCs to attend  training.  Don’t repeat  training forms.

Page 486:  Much is  covered in Person Centered training!  Repetitive.  

Page 486-487:  Writing measurable goals, too wordy.  Use bullets to be concise, give examples of measurable goals.  Covered in other trainings and should be a reminder, not a repeat of training.  

Page 487: Need to include  outcomes a Support Coordinator would use. Example “________receives supports as stated in my plan”  What does that look like? Section appears geared towards providers

Page 487: each CSB/BHA have their own required timelines  for client documentation. Refer  SC to agency’s requirements.

Page 487: There is a Box under Person Centered Reviews  titled “Required ISP Documentation” appears out of place

Page 489:  Service authorizations should only be covered one time.   Wams user guide is repeated. 

Page 489: Regional Support Team- misplaced, doesn’t flow with chapter.

Provide link to WaMS user guide

Eliminate pages in  manual by removing documents  given in person centered training.  Add  link to appendix, remove from manual.  

Page 490-574: Remove. 

Page 575-637: Remove pages from chapter place in  Appendix,

Page 638- 2018 Person Centered ISP Guidance- Add to  resource section/appendix. SC should not be expected to train or correct providers. 

Pages 650-654  good to have but says to hover over the titles for a narrative - doesn’t work, there are comments in red asking questions  appears to be a draft not a final version…finalize.

Page 656: Information on RST misplaced, should come before pages 654-655

Page 658-783: WaMS User Guide –repetitive, remove, place in resource/Appendix section.

Service authorization guidance – useful, add link or to resources/appendix

Page 811: Last sentence: should state “… direct or in person contact … on behalf of the Individuals… “

Page 812:  TIMELY referrals, include timeline,  open to interpretation. 

Page 813:  “Actively observe the person and service providers…”  Clarify, observe in person and the interactions?  Or does through reviewing  plans, phone check ins, etc (not face to face)?  Open to interpretation.

Page 813:  Visiting worksite but intrusive...  offer alternative methods to monitoring workplace, one sentence says to monitor all aspects of client’s life and next sentence it says don’t be intrusive. 

Page 813: Face to Face visits  state every other in the home- reference Emergency Regs.   

Page 814: Skin Breakdown Presentation-make this part of the CM Modules.  Its good information, good place for staff to understand own role.   

Page 814: Add change in hygiene or personal appearance  to bullet points. 

Pages 814-816: Face to Face visits  state every other in the home- reference Emergency Regs. 

Page 816:  “Review the need for ECM on a regular basis…”  Include  link to  updated information.  Section on ECM criteria is confusing when determining  eligibility for  ECM.  Referencing SIS responses/scores which could be 2-3 years old doesn’t  determine current needs.

Page 816: ECM Criteria  last paragraph of who it applies to contradicts page 53 second paragraph of who ECM applies.

Page 819:  “Extended vacation” how is this documented by SC when visit is missed? 

Page 820:  Chart doesn’t print well.  Words cut off.

Page 823:  ECM flow chart – doesn’t print well, difficult to follow.  Could be a great resource if  flow was easier to understand

ECM criteria can be subjective.  CSBs differ in  who may meet criteria, Need a clear checklist or one pager to determine ECM criteria.

ECM Guideline – there are still many questions that need to be finalized before this is added to the manual.  For instance – multiple crisis – how many is that? Interruption of Services – if someone has an interruption (say lack of in home staff) but continues to have day support and/or supported employment is this ECM? Or is it NO Waiver services at all for over 30 days…

Page 821: PCR information  is repetitive, out of place

The format is good, should be modeled throughout entire manual (category, brief explanation, link for the specific regulation or manual)

Page 852: Transfer Policy- in draft, finalize and place in  resource/appendix section.

terminology “mental retardation”  in  transfer procedures needs updating. 

There is reference to modifying  transfer procedures manual. Finalize 

Add requirements for  psychological evaluation when transferring CSBs.

Add information about transitions between private/contract Case Management to CSB Support Coordination.

All embedded resources need it’s own section…

Need  section in chapter about Dual Diagnosis (I/DD and Mental Health). 

Page 867:  Do SCs ever get copies of the CCC+ assessment?  Could this be loaded into WaMS instead?

Page 869:  Proactive Steps to Health good!

Page 871:  Listing reputable sites to check med side effects-helpful.

Page 873-876:  Eight Health Risks very useful; however, should some of these topics be linked to SIS and  exceptional medical needs?  Or is this a resource the case manager can give to others? 

Page 881:  Include legal involvement. Ex., “Past or current legal charges/involvement?  Changes to probation?”

Page 882:  Add CO detector to list. 

Page 883:  Chart is great.  

Page 883: Qularant audits list 8 types of abuse  be consistent with Qularant information.

Chapter is focused on health but not much  is related to safety.  Include more focus on overall safety of clients, DSP, SCs, etc. 

Remove repeated information.  Put  contact information here remove from other sections.  The link is good.  Title it Contact information and community resources, or add to appendix. 

Page 894:  Add “Are there personal care needs?” to questions for considering employment. 

Include Support Coordinators must have consent before talking with providers, employers etc.   

Good information, but not specific to Support Coordinators.  Information may be included in a Supported Employment Manual, but not relevant to SC. Example:  page 896 building a resume, this not something a SC would do.

Page 898:  Discuss with Individual that they may not always be 100% happy in their jobs…  Must be mindful of the SC role to assess satisfaction with services.  The SC is required to give Provider Choice if the Individual expresses dissatisfaction. 

TOO MUCH REPETITION. 

Page 900:  Medicaid non-emergency transportation, the information in this section is misleading and inaccurate.  The manual needs to be realistic with the lack of transportation to and from work.  Suggest that the person call their MCO to discuss employment transportation, or that the caregiver may need to provide transportation, especially in rural areas.   

Page 903:  Like the 1st paragraph clearly explaining the SC role in benefits planning, very good. 

Page 909: “what are employment services and what can I expect?”  who is this for?  Is this supposed to be a resource for the SC to give the Individual/Substitute Decision Maker?

What if DARS says the Individual is not eligible for work, but the Individual wants to work?  Address this and provide alternative options.  If DARS is the gateway to work, then include what the Individual can do if she/he/team disagrees with DARS.

The FAQ section is good, but repetitive. 

Page 914:  also reference local parks and rec programs

Remove the blank pages!!!! 

This is a very good section.  Focuses on the role of the Support Coordinator in clear terms. 

Page 927 repetitive, information is on page 30

Remove page 926, put this link on another page (change the font so it fits)