3.6 Rehabilitation Skill-Building
We would suggest clarification or removal of the last sentence in this section, “All consultation shall be documented in the individual’s medical record.” It is possible we are interpreting this statement incorrectly, in which case we would request re-wording for clarification. Our interpretation of this statement is that internal discussions among CSC team members regarding clinical appropriateness of providing services via telemedicine must be documented on the client record. It is not common practice to document internal team discussions in a client record, and if this is the intent of the statement, we would recommend removal, or at least further clarification for the clinical necessity of this requirement, and why the requirement only appears in this section, and not in all of the other sections where clinical appropriateness for telemedicine is mentioned.
3.8 Crisis Support
We would like to provide positive feedback for all of the clarification efforts in this section and the updates that were made in response to public feedback. The updates are appreciated!
8A- signature of crisis plan by all team members seems excessive, unnecessary, and administratively difficult. We noticed that there were other areas in this 2nd draft manual where signature requirements were reduced, and we recommend that this be updated similarly. We suggest requiring only signatures by the client, legal representative, and the clinician who is completing the crisis plan with the client (QMHP-T clinician or above).
4.1 Coordinated Specialty Care Staffing Requirements
4.1- A “Family Education and Support Specialist” is mentioned as a required qualification of staff, but there is no additional information about what credentials or experience are considered to fulfill this requirement. We are interpreting this list of “staff who fulfill the following roles” moreso as a list of required service components for CSC, but that is already covered in the prior section. We would recommend updating the language here for clarification, or removal, since the prior section 3 covers required service component, and the next subsection, 4.1.1, addressed Required Team members sufficiently.
4.4.1- the list of required components for weekly team meetings, while overall good practice, seems to be excessive oversight of administrative functioning on DMAS’ part. Such stringent control over team meeting structure is not seen in the other programs and services; why is it included in CSC? There may be weeks where not all of these items are discussed in sufficient detail 100% of the time; for example, if there are a high number of high-risk and priority cases, the bulk of the weekly meeting may be spent discussing that, rather than reviewing the treatment plan of each client. Additionally, weekly treatment plan reviews for all clients is excessive as progress toward treatment goals is unlikely to change significantly from week to week. It is recommended that this list of required components be significantly reduced or removed.
4.4.2 Clinical Supervision
It is recommended that the last line of this section, “The RPRS shall be supervised by a professional who has completed the DBHDS Peer Recovery Specialist Training,” be updated to state that the supervisor should have completed Peer Recovery Specialist Supervisor Training. This is an important distinction as the former requires the supervisor to be a peer themselves, while the latter allows clinical supervisors to complete the training. The former would most likely require the RPRS on the CSC team to be supervised by a peer professional outside of the CSC program, which is impractical, while the latter would allow the LMHP Team Leader to directly supervise the RPRS, which is preferred.
5.1 Admission Criteria
5.1.2- it is recommended that the requirement for utilizing the EPSDT be further clarified or removed. Additionally, there seems to be a typo where this says “individuals under the age of 15,” but it is assumed that “21” was intended. It is unclear to our organization how the EPSDT tool is able to be used to “review for medical necessity” as the draft manual states. It is unclear what the connection is between EPSDT screenings and CSC as CSC is not a covered service under EPSDT.
7.2.3 Minimum Service Requirement
It is suggested that the language in this section be updated as there are many appropriate reasons why an individual would receive fewer than 24 months of service (client-elected discharge; relocation out of state; discharge due to non-engagement, etc). If this section was intended to state that MCOs should authorize no fewer than 24 months of service, the language should be updated to make this clearer.