Please consider each of the following concerns:

• DMAS/Therapeutic Consultation Discrepancies - We understand there may be one official way that each task should be done (According to the DMAS regulations or in the Therapeutic consultation guidelines documents), but support coordinators /DMAS/DBHDS representatives constantly give us conflicting information.

• 1. Support coordinators have told us that Interim Support Plans need to be done at the beginning of each authorization for all clients, others have said only for a new client, and others have said only at the beginning of an ISP period for a new or existing client.

• 2. We have been told for some clients that they want to review data/graphs for previous treatment periods, and other DBHDS have asked us to only show recommendations for the caregivers for the next period and no data.

• 3. We have been told that a full assessment/FBA is required at the start, and we have also been told that all we need at the start is to say “an FBA will be completed” within our interim plan, and not conduct one until later.

• 4. We often receive denials that our requested dates of service don’t line up with the individuals ISP date (that was written by another DMAS representative) – If these dates only align with the individuals plan, we understand that it is posted for us to see that date, however we are being requested to initiate services with clients sometimes approximately 4-6 weeks before  one of these dates, and it is not clinically appropriate to write a treatment plan and start services just for a  few weeks before having to pause and go through the process again. We understand this is likely how DMAS sets up the individuals benefits, however it would be helpful if our Treatment/Support Plan and services were separate and would initiate from the time we are approached by a family/support coordinator, and consistently are for 6 month periods as opposed to having to follow some other time line that does not match the client’s needs. 
  5. We have received feedback from two different support coordinators in which one said nothing is required for Discharge, and the other said “discharge summary/disposition Summary along with Final Quarterly Review for Behavior Consultation and any Consultant recommendations.” This is not consistent

6. We have had multiple clients to which family and DMAS support coordinator agreed on a goal of obtaining employment opportunities for the individual, EMPLOYMENT is even an option to select under “Life Skill Area,” however we also received a denial from one DBHDS stating a goal related to employment is “Not appropriate for this service.” Very conflicting!

7. TC Service Criteria ­ – It is quite limiting (regarding how many families can receive support in our community) that only BCBAs can directly provide the service. We understand that the nature of Therapeutic Consultation Services is for caregiver training, however the client’s name (and not the Caregiver) is listed as the direct client, with goals related to “Life areas” of improvement for client, are interpreted by providers as being able to provide direct support WITH the client instead of only just the  caregiver, so a lower-level certification (E.g. a certified RBT) could also be effective in this role with direct support from the BCBA regarding all interventions and recommendations, and allow more clients to access this service.