Chapter IV

1. Pg. 20 – Please clarify that a Comprehensive Needs Assessment is only “outdated” following a lapse of all (or the only) CMHRS service that are being provided within the same agency. A Comprehensive Needs Assessment can remain valid if providing multiple services and only one of those services has lapsed (see 11/20/19 Medicaid Memo, pg. 5 and training slides 42-44).
2. Pg. 20 – Please clarify the “annual review and update” requirement:

   • The language in the 11/20/18 Medicaid Memo reads “At a minimum, the Comprehensive Needs Assessment must be reviewed annually”. However, as written here it can be interpreted that an “annual review and update” is required every 365 days from the date of the initial Comprehensive Needs Assessment regardless of when the last face-to-face Review and Update (Reassessment) was completed. Our understanding from the Memo and training was that as long as the Comprehensive Needs Assessment has been reviewed and updated by a face-to-face reassessment within the last year, it remains a “valid” assessment.

   • Providers have been required by the BHSA and MCOs to bill for an assessment annually in order to continue services beyond 12 months. Will the BHSA and MCOs continue to reimburse for services after 12 months without receiving a claim for an Assessment?

3. Pg. 20-21 – Please clarify the need for a “new” Assessment verses just a “review and update” when services have not been provided for 31 calendar days.  Pg. 20 indicates that an Assessment is no longer valid when the provider has not provided a CMHRS service recommended by the Comprehensive Needs Assessment in the past 31 calendar days.  However, pg. 21 indicates that if services have not been initiated within the past 31 calendar days, they only need to “review and update” the Assessment as long as the Assessment is still valid.  When would the Assessment be valid in this scenario since you’ve already defined a lapse in service of 31 calendar days as rendering the Assessment "outdated" and "invalid"?  Is a “review and update” only allowed when more than one CMHRS service was recommended in the Comprehensive Needs Assessment and only one of those services was not initiated within the 31 days?

4. Pg. 21 – “A LMHP, LMHP-R, LMHP-RP or LMHP-S may update an existing, valid Comprehensive Needs Assessment as defined above to continue providing a CMHRS service after a member is discharged from the service”.  Does this only apply when 1) the individual is discharged for reasons other than a 31+ day lapse in service since that automatically invalidates the Assessment, or 2) if providing more than one CMHRS service and only discharged from one service?