Ch. II p. 8 regarding adverse outcomes. Language does not reflect current standardized guidance regarding critical incident reporting to MCOs. Language is not clearly defined for what meets criteria for reporting. Language surrounding incidents of violence initiated by the member has been removed critical incident reporting guidance document. Language should be consistent with critical incident reporting guidance.

Ch IV p. 14 regarding DLA-20 may be used as CNA if it covers all 15 elements or addendum can be done to cover elements. This could potentially assist to streamline documentation. However, is DBHDS Office on Licensing going to recognize DLA-20 standard assessment as meeting all requirements for assessment under 12VAC35-105-650.

Appendix D p. 15 #4: “The individualized treatment plan, updated every 30 days or as clinically appropriate…” Please clarify if the requirement is that each individual’s treatment plan will be updated at least every 30 days? Requiring treatment plan update every 30 days at a minimum places additional administrative burden on ACT teams. Recommend that treatment plan updates should occur as clinically appropriate or at least every 90 days.

Current regulations require new CNA to be completed if no CMHRS services were provided in 31 days. Recommend that an addendum be considered as sufficient in these circumstances as long as there is a full CNA that has been completed within the last year. In general, language around when a new CNA is to be completed and when an addendum is sufficient is confusing and appears to contradict itself within the regulations. Requiring a new CNA if gap in service of 31 days places additional administrative burden on both employees, individuals, and families.