This section provides another example where terms are used that are not generally understood and used by providers. The term “referral update,” better reflects what providers understand to be the documentation requirements outlined in the proposed regulations. For this reason, we recommend replacing the terms “secondary screening” with “referral update” throughout this section. The line-by-line comments reflect this suggested change.
Also in this section, greater clarity is requested around whether the initial referral is acceptable in cases where a provider has no waitlist.
Clarity is also requested with respect to how long a person must be on a waitlist to trigger the requirement for a secondary screening or referral update.