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Virginia Regulatory Town Hall
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Board of Medical Assistance Services
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5/13/21  5:01 pm
Commenter: tamara starnes

ACT Appendix D additional

Lists Group as required activity: Recommend clarification that Group is available (not all will need this service, treatment should be individualized)

Notes “Will” provide Group and Individual modalities for people with co-occurring. This will depend on client preferences; reword to note “availability” versus will, treatment should be based on choice and individualized needs, not all do well in groups for example.


Recommend changing to “billed” only for the below excerpt: Person may have an authorization for ACT for example, then need MH Partial Hospital and the authorizations overlap because they are given in advanced time frames.  Also strike through Crisis Intervention as person may end up in ED and need Prescreening.


“ACT may not be authorized or billed concurrently with Individual, Group or Family Therapy, Addiction and Recovery Treatment Services (ARTS) and Mental Health (MH) Intensive Outpatient, ARTS and MH Partial Hospitalization Program, Outpatient Medication Management, Therapeutic Day Treatment, Intensive In Home Services, Crisis Intervention, Crisis Stabilization, Mental Health Skill Building, Psychiatric Residential Treatment Facility (PRTF) and ARTS Level 3.3-3.7 or Peer Recovery Support Services, as the activities of these services are included in the per diem.”


The above is especially important per this part of the manual: Continuation of services may be service authorized at one year intervals based on written service-specific provider re-assessment and certification of need by an LMHP.


Concerned the below will be taken as a regulation versus recommendation, does not seem needed/appropriate for regs. Have been on ACT teams that accepted many more than 4 per month in the first year. This recommendation would lead to only 12 cases total after 3 months, in some case, to a 1:1 staffing ratio.  “To ensure appropriate ACT team development, each new ACT team is recommended to titrate ACT intakes (no more than 4 total per month)”


Concerned this will be interpreted as must be updated every 30 days. Suggest using same standards as other outpatient services.  Reference: “The individualized treatment plan, updated every 30 days or as clinically appropriate”


Suggest taking out the words “vigorous” an “ongoing” as ACT is one of the longer- term treatment services available to help with sustained recovery. Transition from this level of service, compared to all others, should be slow and well thought out. “Coordination of care and vigorous, active discharge planning are documented and ongoing from the day of admission with the goal of transitioning individual to a less intensive level of care”. And especially considering the next section “Individuals should therefore not be discharged from the service due to perceived “lack of compliance” with a treatment plan or challenges integrating interventions into their lives towards recovery.”


CommentID: 98525