Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
Previous Comment     Next Comment     Back to List of Comments
9/16/21  12:52 pm
Commenter: Brandon Rodgers

Comprehensive Crisis Services
 

At the start of services, a LMHP, LMHP-R, LMHP-RP, LMHP-S or Certified Pre-Screener must conduct an assessment to determine the individual’s appropriateness for the service. This assessment must be done in-person or through a telehealth assisted assessment. A Level of Care Utilization System (LOCUS) assessment can be used to meet this requirement if conducted by a LMHP, LMHP-R, LMHP-RP, LMHP-S or Certified Pre-Screener.

The language "at the start of services" is cumbersome in many of the crisis services, in particular 23-hr Observation - during which Peer Supports and other services may precede the full assessment as a means of providing a suitable environment and rapport at the initiation of services before a formal assessment can occur. Crisis services are designed to intervene through well established best practices.

The Crisis Education and Prevention Plan (CEPP) is required for Community Stabilization. It must meet DBHDS requirements, is required during the entire duration of any crisis service, and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S.

A CEPP is traditionally a fluid document that can take up to 15 days to develop in provisional form, please provide clarification on requirement for the CEPP to be in place during the entire duration of service.  Also, a CEPP is able to be developed by a Peer, QMHP, QIDP, etc. that has developed an understanding of the unique needs of the individual, including review of the assessment by a LMHP type.  Requiring direction to by a LMHP type is overly cumbersome in the provision of these supports and devalues the care provided by Peer and QMHP/QIDP staff.

CommentID: 100005