Location

Concern

Note/Comment

General Comment

Not recognizing a Comprehensive Assessment (initial, update or review) completed by a Qualified Mental Health Case Manager for any other service than Mental Health Case Management.

A case manager’s role and responsibility is to assess an individual’s service and support needs and connect the individual with services.  Not recognizing the Case Manager’s Assessment as the assessment for the individual, impedes the Case Manager’s ability to fulfill their role. It is appropriate for the Qualified Mental Health Case Manager to complete the overall sections of the CNA, and the LMHP type render diagnosis.  Then allow a LMHP for services (outside of Case Management) to review the CNA completed by the Qualified Mental Health Case Manager, update as appropriate and then identify how the individual qualifies for the other CMHRS service(s).

Ch. II, Ch. IV

No definition of Qualified Mental Health Case Manager included.

Add a definition for Qualified Mental Health Case Manager based on the information included in the manuals.

Ch. II,

Exhibit Page 1

Table of Contents indicates a Provider Risk Attachment is included as Exhibit 2.

The Provider Risk Attachment is not in manual.

Ch. IV, Page 6

Definition of Comprehensive Needs Assessment does not include that a Qualified Mental Health Case Manager may complete the Comprehensive Needs Assessment for Mental Health Case Management Service.

Concern with Comprehensive Needs Assessment element 15. 

Amend definition to include a Qualified Mental Health Case Manager can complete Comprehensive Needs Assessment for MH Case Management.

See comment below regarding amending element 15 for Comprehensive Needs Assessments completed for Mental Health Case Management Services only.

Ch. IV,

Page 13-14

Concern with wording requiring saying DBHDS agencies SHALL use a single comprehensive needs assessment.

The SHALL should be changed to MAY.  Agencies may make the determination for their practices and staffing to use separate documents.  As long as the document includes the required information, this should be an agency determination.

Ch. IV, Page 19

Comprehensive Needs Assessment element 15 indicates a dated signature of the LMHP, LMHP-R, LMHP-RP or LMHP-S is required.  However, this is not required for Comprehensive Needs Assessment needed for Mental Health Case Management.

Amend element 15 to indicate the signature of a Qualified Mental Health Case Manager meets requirement for Comprehensive Needs Assessment completed for Mental Health Case Management.

Ch. IV, Page 19-22

Exclusion of information that a Comprehensive Needs Assessment (and annual review) completed and signed by a Qualified Mental Health Case Manager is considered current and valid in the sections defining: (1) A valid, current Comprehensive Needs Assessment; (2) When a reassessment must be completed; (3) Who may conduct the reassessment; (4) How the annual review must be conducted; and (5) The times when a Comprehensive Needs Assessment must be reviewed.

Ensure it is clearly indicated an initial Comprehensive Needs Assessment, annual review and other reassessment completed and signed by a Qualified Mental Case Manager is considered a current, valid Assessment for Mental Case Management service.

Ch. VI Page 13

This section indicates all ISPs must be signed and dated by the LMHP, LMHP-S, LMHP-R, LMHP-RP, QMHP-A, QMHP-C, or QMHP- E preparing the ISP within 30 days; This is not true for Mental Health Case Management Services.

Amend section to indicate a Qualified Mental Health Case Manager must complete and sign the ISP for Mental Health Case Management Services within 30 days.