The following outlines our comments in this section:
The term “screening” as described in this section is not a generally recognized term for providers. The minimum elements outlined in this section are generally characterized as the “initial referral,” for providers and therefore, we suggest the regulations be changed to reflect this.
In the minimum required elements for the screening or initial referral, we suggest changing (b) to read “legal and preferred name, date of birth, sex and gender.” This ensures providers know the individual’s legal name, which is likely how Medicaid recognizes them, but also allows providers to know their preferred name. In addition, we believe it would be more appropriate to remove the terms “biological” from sex, and “orientation” from gender.
Also in the minimum required elements, we suggest changing (e) to read, “reported diagnosis,” because at this point in the process, a provider is likely relying on what the individual and/or person (people) who accompanies them is reporting to them.