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3/6/19  4:34 pm
Commenter: Susan Hoover, RBHA

comments regarding draft CMHRS services
 

The definition of qualified mental health case manager was not included in  the providers credential section chapter 2 page 10.

The activities/services provided by a case manager include assessment and planning of services and development of a person centered ISP.  Case manager’s play an integral role in assessing the functional needs of individuals served include  areas of daily living, coping skills, mental and physical health care practices, time management, money management ,  problem solving/counseling.  Therefore, after the initial CNA,    the MHCM should be able to complete the addendum for additional CMHRS services with review and certification by LMHP or LMHP-E, that the individual meets medical necessity.

Please provide clarification of CNA  after discharge.  Does this mean if an individual is discharged from a program, not receiving any other  CMHRS services and then decides they want to return to services, a new CNA  is not required as long as the current CNA  is valid?  How is this different then a lapse of 31 days?

Draft regulation states that a single CNA shall be used per provider.  We have received written communication they we may conduct separate CNAs per CMHRS based on our staffing and business operations.  Please clarify.

The DLA 20 is a functional assessment and Outcome measure proven to reliably estimate individual functioning in 20 different areas of daily living.  The DLA 20 should be allowed to serve as the assessment/addendum for CMHRS particularly MHSB and PSR.