The tiered levels of rehab services could be positive. Would like a strong orientation that stability is a viable goal and incorporate the premise that some consumers require a low level of services to maintain stability over the course of their lifetime. The mention of longer-term maintenance support and clubhouse model in regards to PSR services is critical to building out the entirety of the care model. We would like to see more wrap around supports within PSR (peer/CM/therapy) without losing PSR billing to provide more integrative services for our members.
Artificially capping caseload sizes does not account for - individual acuity/clinical needs of consumer, tenure/seasoned vs new clinicians, supervision needs of the Qs or Ls (or even BHA/Ts) / how many employees can be under one supervisor, sudden changes in workforce resources, and overall business operation demands (short & long-term). Caseload sizes should be recommendations not regulated by DMAS.
NOT the CANS. The CANS is not a clinical assessment that focuses on diagnostic and psychosocial to determine the diagnosis and mental health needs; only reflects surface strengths and weaknesses and misses underlying issues.
Strongly support building peer services into the structure of services such that the cost is built into the reimbursement rate. Note - it is very difficult to find peers for youth. Maybe this should be optional versus built in; or at the very least a tiered model with and without peers.
Strongly support incorporating EBPs - EMDR, PCIT, CBT, DBT, etc. The struggle is the cost of the training - actual training fees and cost of taking clinicians off-line for the training and the on-going required (specialized) supervision, refresh-type training, and the turnover within departments that equates to an on-going cycle of training costs for the same service....all non-billable. So if EBPs are mandated, there should be a long lead time to get clinicians adequately trained to provide the service in a responsible manner across the Commonwealth.
