Virginia Regulatory Town Hall
 
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Waivered Services [12 VAC 30 ‑ 120]
Action Three Waivers (ID, DD, DS) Redesign
Stage Proposed
Comment Period Ended on 4/5/2019
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4/4/19  8:57 am
Commenter: Darcy Creech

Therapeutic Consultation
 

Please see below for suggestions/comments regarding Therapeutic Consultation Services unde the DD Waiver 

 

B. Criteria and allowable activities.

1. To qualify for therapeutic consultation service, the individual shall have a documented need for consultation. Documented need shall indicate that the ISP cannot be implemented effectively and efficiently without such consultation as provided by this covered service and approved through service authorization. The need for this service shall be based on the individual's ISP and shall be provided to an individual for whom specialized consultation is clinically necessary. Therapeutic consultation service may be provided in individuals' homes and in appropriate community settings, such as licensed or approved homes or day support programs, as long as they are intended to facilitate implementation of individuals' desired outcomes as identified in their ISP.

2. Allowable activities for this service shall include:

a. Interviewing the individual, family members, caregivers, and relevant others to identify issues to be addressed and desired outcomes of consultation;

b. Observing the individual in daily activities and natural environments and observing and assessing the current interventions, support strategies, or assistive devices being used with the individual;

c. Assessing the individual's need for an assistive device for a modification or adjustment of an assistive device, or both, in the environment or service, including reviewing documentation and evaluating the efficacy of assistive devices and interventions identified in the therapeutic consultation plan;

d. Developing data collection mechanisms and collecting baseline data as appropriate for the type of consultation service provided;

e. Designing a written therapeutic consultation plan detailing the interventions, environmental adaptations, and support strategies to address the identified issues and desired outcomes, including recommendations related to specific devices, technology, or adaptation of other training programs or activities. The plan may recommend training relevant persons to better support the individual simply by observing the individual's environment, daily routines, and personal interactions;

f. Demonstrating (i) specialized, therapeutic interventions; (ii) individualized supports; or (iii) assistive devices;

g. Training family/caregivers and other relevant persons to assist the individual in using an assistive device; to implement specialized, therapeutic interventions; or to adjust currently utilized support techniques;

h. Intervening directly, by behavioral consultants, with the individual and demonstrating to family/caregivers or staff such interventions. Such intervention modalities shall relate to the individual's identified behavioral needs as detailed in established specific goals and procedures set out in the ISP; and

i. Consulting related to person centered therapeutic outcomes, in person or over the phone.

 

Comment:  Suggest adding “and/or by video” to allowable activity B2i

 

C. Service units and limits.

1. The unit of service shall be one hour.

 

Comment:  The unit of service should be 15 minutes rather than one hour.  This would cause less confusion on what to do if the service was provided for less or more than one hour and better account for phone call consultation.

 

2. The servics shall be explicitly detailed in the plan for supports.

 

Comment:  services is spelled incorrectly

 

3. Travel time, written preparation, and telephone communication shall be considered as in-kind expenses within therapeutic consultation service and shall not be reimbursed as separate items.

 

Comment:  This statement contradicts B2i above.  Suggest removing “telephone communication”

 

E. Service documentation and requirements.

1. Providers shall include signed and dated documentation of the following in each individual's record:

a. A copy of the completed age-appropriate assessment as detailed in 12VAC30-122-200.

 

Comment:  The SIS assessment is not unique to this service and it is redundant to include it in the individual’s therapeutic consultation record. While this document may be helpful in the assessment, it does not define how services are conducted, the amount of services needed or approved, and does not effect funding under therapeutic consultation services so should not be required to be in the client file under therapeutic consultation. 

 

b. A plan for support, that contains at a minimum the following elements:

(1) Identifying information;

(2) Desired outcomes, support activities, and timeframes; and

(3) Specific consultation activities.

c. A written therapeutic consultation support plan detailing the recommended interventions or support strategies for providers and family/caregivers to better support the individual enrolled in the waiver in the service.

 

Comment:  Suggest adding more guidelines for the support plan to set standards and protect the waiver recipient.  Each profession should have different guidelines for the plan.  Behavior Consultation Plans for Support should include the following at a minimum:

  • Target behaviors and definitions; includes both behaviors targeted for reduction and replacement behaviors
  • Results of functional assessment, including function, type of assessment, dates, location, who participated, etc.
  • Behavioral objectives
  • Baseline data (could be from assessment)
  • Data collection methods
  • Clear description of treatment methods for behavior reduction and skill acquisition including antecedent and consequence procedures/protocols for each target behavior
  • Functional reinforcer is identified for each behavior targeted for reduction
  • Possible reinforcers (results from pref assessment) and schedule of reinforcement
  • Generalization and maintenance strategies
  • Medical contraindication
  • Crisis management (what to do when individual is not responding to BSP and is a danger to self and/or others.
  • Criteria for discharge
  • Benefits and risks associated with treatment and for not receiving treatment
  • Signatures indicating consent from team members and from individual/legal guardian

 

 

d. Ongoing progress note documentation of rendered consultative service that may be in the form of contact-by-contact or monthly notes that must be contemporaneously signed and dated, that identify each contact, the amount of time spent on the activity, what was accomplished, and the professional who made the contact and rendered the service.

e. If the consultation service extends three months or longer, written quarterly reviews that are completed by the provider and forwarded to the support coordinator. If the consultation service extends beyond one year or when there are changes to the plan for supports, the plan for supports shall be reviewed by the provider with the individual, individual's family/caregiver, as appropriate, and the support coordinator and shall be submitted to the support coordinator for service authorization, as appropriate.

 

Comment:  The quarterly reports are actually due three months after the person-centered planning date, which is determined by the Support Coordinator.  Suggest:  “Quarterly reviews are completed by the provider using the quarterly schedule based on dates on the Person Centered Plan. A 10-day grace period is permitted, after

which the provider should immediately forward the quarterly report to the Support Coordinator” . . . or something that lets providers know that they need to follow the same schedule.

In addition, all quarterly reports must include data in the form of charts, graphs, or other measures that show that the plan is effective, or if ineffective, how the provider plans to change the service to make it effective.

The previous manual had a better guideline regarding timeframes and contents:

The previous manual stated:

Person centered review (quarterly) documentation must include:

a. Any revisions to the therapeutic consultation Plan for Supports;

b. Activities related to the therapeutic consultation supporting

documentation;

c. Individual status and satisfaction with services; and

d. Consultation outcomes or effectiveness of the consultation support plan.

 

The due date for the person-centered review (quarterly) is determined by the effective

start date of the Individual Support Plan, which is communicated to the

provider by the case manager. A 10-day grace period is permitted, after

which the provider should immediately forward the person-centered review to

the case manager.

CommentID: 70881