Action | 2011 Mental Health Services Program Changes for Appropriate Utilization & Provider Qualifications |
Stage | Proposed |
Comment Period | Ended on 4/12/2013 |
Alexandria CSB Comments to DMAS on Proposed 2011 Mental Health Services Program Changes
12VAC30-30-60-143 – PCP: Support PCP Notification with appropriate client Authorizations in place.
12VA30-50-130-5-ISP: ISP Providers with EHR’s will need time to reconfigure system capabilities to meet any new requirements. Discharge plans are currently included in a variety of ways including in ongoing assessments.
12VAC30-50-130-5 - Community Mental Health Services: Community Mental Health Services The term "certified pre-screener" is a term that, in Virginia, is considered to be exclusive to the CSB/BHA clinicians who provide emergency services and pre-admission screening for involuntary detention. This proposed change would be in conflict with the current Code of Virginia and DBHDS Licensing Regulations and removes the CSB/BHA designation as the sole entity to fill the role of certified pre-screener.
12VAC30-50-130-5 - Intensive In-Home: Intensive In-Home (IIH) is one of the most intensive community based mental health services provided to children and adolescents with serious emotional disorders (SED). SEDs are chronic conditions that persist over time and it is essential that children and adolescents with SED receive targeted case management services independent of IIH to ensure that clinical needs of these children and adolescents are being met effectively, coordinated and addressed.
12VAC30-50-130-5 - LMHP: LMHP – Substance Abuse practitioners are certified not licensed. Does this mean that services provided by the CSAC will no longer be eligible for reimbursement?
12VAC30-50-130-5 - QMHP-C: How will grandfathering and variances be handled related to staff already hired – this is a critical issue. This change will impact the pool of potential staff and adversely affect recruitment.
12VAC30-50-130-5 - Work Experience: Requiring “full time experience” would reduce the pool of potential staff and adversely affect recruitment (i.e. caregivers, part-time workers). There is also need for guidance on the calculation of “clinical experience”. There needs to be a clear definition of the meaning of “supervised”. Also, what is the expectation of how internships, outside of the hiring entity, would be handled or documented?
12VA30-130-3010 - ICA: Removes the CSB/BHA designation as the sole entity authorized to perform independent clinical assessments.
12VA30-130-3030A – Intensive In-Home: IIH -Removes the CSB/BHA designation as the sole entity authorized to perform
12VAC30-50-226 - Crisis Services: Crisis Intervention and Crisis Stabilization proposed requirements for "Registering" with DMAS should be expected only after the crisis intervention has been accomplished; within a designated timeframe. Additional information about how the registration information will be transmitted to and used by DMAS, as well as staff training will need to be provided.
12VAC30-50-226 - Intensive In-Home Services: Intensive In-Home Services should allow LMHP-e (licensed eligible) to complete face-to-face assessments with approval/sign-off from a LMHP.
12VA30-50-226 – ISP: Loss of person centered language is very concerning. This should be added back into this section as should the assurance that the recipient is part of service planning. In addition, providers with EHR’s will need time to reconfigure to meet any new requirements.
12VA30-50-226 – ISP: Providers with EHR’s will need time to reconfigure to meet any new requirements.
12VAC30-50-226A - Certified Pre-screener: The term "Certified Pre-screener" - should be consistent with the Code of Virginia. The proposed change would be in conflict with the current code of Virginia and DBHDS licensing regulations, under which only CSBs/BHAs can perform this service.
12VAC30-50-226A - Certified pre-screener: Suggest the language be amended in each section where it is used to be clear about the entity and the precise function. Do not use the term “certified pre-screener” unless it is accompanied by the prefix “CSB/BHA”. Suggest wording be reworked to clarify the Certified Pre-screener role is exclusive to the CSB.BHA.
12VAC30-50-226A – QMHP-A and C: How will grandfathering and variances be handled related to staff already hired – this is a critical issue. This change will impact the pool of potential staff and adversely affect recruitment.
12VAC30-50-226A - Work Experience: Requiring “full time experience” and not considering part-time experience would dangerously reduce the pool of potential staff and would adversely affect recruitment of many qualified people who have gained experience as caregivers or part-time staff.
12VAC30-50-226A-Registration: When CSB/BHA clinicians are addressing emergency situations, triage and stabilization should be allowed and followed by Registration, as explained in our comments below.
12VAC30-5-226B1-Service-specific provider assessment: Please clarify. Is this the same as a comprehensive assessment? And should the assessment include specifically the behavioral and primary health needs in “health status”?
12VAC30-50-226B -Crisis Intervention: Amount of service that will be needed and provided can hardly be determined in advance. Individuals in crisis can rarely provide comprehensive information so triage and stabilization is necessary before registration of any kind.
12VAC-50-130 - Activities of Daily Living: Proposed regulations state “Activities of daily living means personal care activities and includes bathing, dressing, transferring, toileting, feeding, and eating.” VACSB suggests that the list of allowable activities of daily living should be expanded to include shopping, budgeting, meal planning, and medication management, all of which are essential activities for individuals with Serious Mental Illness. As well, include the language for Instrumental Activity of Daily Living (IADLs).
12VAC30-5-226B - QMHP-A: There is a need to clarify that a QMHP-A can continue to conduct the face to face assessment with the LMHP approval.
12VAC30-60-61A - Definition of “at risk”: This more stringent definition in the proposed changes may easily result in fewer children and adolescents with SED qualifying for Intensive In-Home. If a service model such as the Strategic Family Services and Supports Services Model, designed by the VACSB and endorsed by Voices for Virginia’s Children, were available, this “at-risk” definition may not have the potential to deny services to those who need them. That model is not in place, however, and outpatient, clinic-based services may not meet the needs of children and adolescents with SED in Virginia. Flexibility and an exception process are needed.
12VAC30-60-143 - PCP Notification: With language that assures recipient’s consent to the notification, fully support coordination with PCP.
The Alexandria Community Services Board endorses the general comments submitted by the Virginia Association of Community Services Boards as reflecting the concerns of our CSB. Specifically, those comments are: