As noted in the VACBP's comments in the definitions section, we believe it’s important that providers understand that this section is describing the “Comprehensive Needs Assessment,” as opposed to an additional or different assessment. For this reason, we suggest amending this section to replace the term, “assessment,” with as “Comprehensive Needs Assessment” or “CNA.”
Within (F) of this section regarding the “initial assessment,” we propose including “as available” when directing providers to obtain information from other qualified providers, recognizing that it can be challenging to obtain this information.
Also within (F) of this section, we propose adding (3) that states that, “An initial assessment shall not be required for Mental Health Outpatient services.” The rationale for this suggestion is that service authorizations are not required for mental health outpatient services, so the development of the described “initial assessment” may not be necessary.
Within (G) of this section regarding the “comprehensive needs assessment,” we propose adding the words, “as available,” to (5), recognizing that previous assessments of an individual are not always available or easy to obtain.
Also within (G) of this section, greater clarity regarding how “legal competency” is defined in this context is requested.
