Virginia CSBs support the establishment of Re-entry Targeted Case Management and the draft's emphasis on pre-release engagement, medication continuity, person-centered planning, and a warm handoff to managed care. Before implementation, DMAS should revise the supplement to prevent avoidable service gaps and financial loss. Specifically, DMAS should permit immediate, non-duplicative transition to ongoing targeted case management; reconsider the same-calendar-month exclusion; extend the one-business-day registration deadline and add good-cause relief; establish reciprocal timeframes for correctional records and MCO participation; clarify eligibility, reassessment, discharge, and monthly billing rules; and publish adequate rates and operational guidance. CSBs should receive at least 90 days after release of the final clean supplement, rates, billing specifications, and training to implement compliant workflows and EHR changes.

DMAS should coordinate with DBHDS Licensing to clarify how CSBs may provide RTCM to eligible individuals who do not meet the diagnostic or admission criteria reflected in their existing case management licenses and program descriptions. The agencies should resolve any conflicting requirements and provide consistent written guidance to CSBs and licensing staff, including any necessary program description changes, so that serving RTCM-eligible individuals does not result in licensing citations.