DMAS’s willingness to streamline the assessment and intake process for individuals receiving services is greatly appreciated and we believe this will facilitate a more timely delivery of services. Additional efficiency could be enacted for both providers and DMAS if a single assessment rate were established for all CMHR services with the exception of Mental Health Case Management, vs. billing as service delivery time for the highest paying service an individual receives. This rate should be established with respect for the additional education, credentials, and clinical knowledge of the licensed/licensed eligible clinicians required to conduct these assessments and with recognition that the increasing expectations for involvement of LMHP/LMHP-types across a variety of services has impacted the pool of available clinical staff, with a ripple effect of impact on ability to offer services. The recommendation is to use CPT code 90791 or a similar code for this annual assessment.
We further recommend that the expectation for the quarterly review of an ISP not include the specification that this occur on the 90th calendar day. Simply specifying that this is a quarterly requirement, with a 15 day grace period (other than for case management which requires a longer grace period) will increase uniformity across DMAS requirements (e.g. with DD Services) without any negative impact to individuals served.
In addition, there are a few points regarding which clarification is requested. First, pages 21, 33-34, 49-50, and 56 specify a need for review and demonstration of continued need at the six month mark for the following services: MHSS, PSR, and ICT. In situations where a single provider provides more than one of these services to a particular individual, please clarify that a single review that speaks to the person’s need for the various services is acceptable; this is apparent in the FAQs, but not in the manual itself. This would further streamline the time of LMHPs/LMHP-types, eliminate redundant documentation and potentially streamline time for individuals served (i.e. when a face-to-face review is indicated).
Second, page 49 of Chapter IV states that individuals who meet the medical necessity criteria to receive ICT services “may also simultaneously be approved for” Case Management services. However, Licensure regulation 12VAC35-105-1410 clearly states that case management services are part of ICT/PACT service requirements and providers are held to that standard.
Inconsistent information is present regarding expectations for the content of ISPs. Although page 23 of Chapter describes basic components of an ISP and then refers the reader to DBHDS Licensing requirements of 12VAC35-105-665, pages 7 and 24-25 articulate a series of requirements not wholly consistent with the Licensing requirements. The effort to increase consistency with Licensing’s requirements is also appreciated and we request that there be further collaboration with DBHDS to ensure the two sets of expectations are consistent.
Finally, although it is our understanding that credentials are now being defined by the Department of Health Professions, some of the definitions refer the reader to the Licensing regulations, which have not yet been completely updated to match those of the DHP.