Page 16:

“Please note that Preferred OBOTs and OTPs are required to develop an Individual Service Plan (ISP) within 24 hours from intake and an Interdisciplinary Plan of Care (IPOC) within 30 calendar days an updated at a minimum every 90 calendar days.”

VS.

Page 24:

“Develop and maintain the DMAS Individualized Plan of Care (IPOC) within 30 calendar days from the ISP assessment date if billing Substance Use Care Coordination and ongoing every 90 calendar days. Providers may use the DMAS IPOC form but not required.”

Comments: Clarification is needed between these 2 statements as current standards require updates to IPOC every 30 days. Does this effect billing being limited to every 90 days or 30-90 days? Programs should not be limited to only providing this service every 90 days as evidence shows that we are able to provide a better level of care when care coordination includes IPOC review monthly. 

Page 26:

“o DMAS requires individualized substance use disorder counseling and/or psychotherapy to be provided along with pharmacotherapy. However, DMAS recognizes not all members are ready to engage in counseling or psychotherapy. Providers shall document continuous efforts to engage members in treatment utilizing motivational interviewing techniques, relapse prevention strategies, etc. and are not required to discharge members from pharmacotherapy during this period.”

Comments: Clearer definition is needed as it stated as a requirement, but programs are also not required to discharge members if not engaging. Is there a time frame for which members are given the opportunity to participate in counseling or is it just not a requirement at all if the member prefers not to? How is a program supposed to encourage a member to participate in counseling if they cannot be discharged or referred to a higher level of care- then it is not a requirement.  Isn’t this also part of the ”evidence based” treatment model?  We fear members will understand this to say that therapy is optional, and many will decide not to participate, simple human nature of “I am too busy” etc.  We fear this then could lead to higher relapse rates.  As suggestion would be to allow for a longer time to enroll in counseling, a new member shall enroll, participate within perhaps 30 to 90 days of starting the program.

It is also noted in accordance with other commenters that changes in the definition to CATP’s exclude CSAC’s and throughout the manual CSAC’s have been restricted in services they are able to provide. In acknowledging that staffing requirements are one of the largest obstacles in expanding services and programs, we urge that CSAC’s not be limited in this way so that they may be fully utilized by providers.