I am in favor of an extension of the quarterly review

inorder to get three whole months documented and get signatures from parents , AR , guardians and

get the documentation into a chart whether in electronic record keeping chart or  the individual 

binder. I am not sure of how much time is being proposed but please allow for an extension of time 

that allows for the entire process to take place in

a manner that does not have conflicts in delivery of a

3 month time frame.

Dr. Alexander Moore

302-423-8870

Over the last 5 -7 years there has been a shift in community mental health. Particularly in the last 6 months the shift for private providers dealing with not only DBHDS and DMAS regulations but also now MCO (managed care organizations) regulations has become the biggest administrative burden. While this town hall comment is not necessarily here for that topic it sets the stage for politicians to understand the climate of community behavioral health right now. The focus from true care to worrying about paperwork constantly for 3 (4 if you count human rights) different types of regulatory entities takes so much away from actually helping people. There should absolutely be regulations and rules to follow so that private providers like myself can follow ethical guidelines and demonstrate quality care. However, when the focus shifts from the client and what they need to meeting a deadline all the time it is very burdensome. ISP's should be revised. I tell my staff they are a working document. The burden of counting out exactly 90 days for a review and then ensure whether it snows, hails, sleets, etc we see them on the 90th day to get a signature and finalize review is really not therapeutic at all. If the focus was on the actual ISP and reviewing it as needs changed or even allowing for the administrative time to review it and obtain signatures around the 90 day period (maybe a 30 day grace period) then it may become a more useful document. There is no point in an ISP every 90 days when people are just doing it to do it and say it was done. If we had more flexibility as the provider to have more time to revise it, review it, and obtain signatures within a grace period than the quality of care I believe would increase. 

Now the only downfall to all of those thoughts are that the MCO's now want the ISP to accompany the Service Authorization request. Those requests go in every 90 days so you may run into issues if the ISP has not been revised in time. 

Overall, it sucks that all 4 entities plus MCO's are not on the same page at all about regulations that are in black and white and those that we are trying to serve are greatly affected by it. People being denied for services left and right because they have had them for "too long" or "the service failed"... after 18 months. I have so many "stories" that are real clients lives that are being affected by these ridiculous decisions. Big money companies are just trying to save the government money. I envision within a few years we will be back like the settlement days with mentally ill individuals walking the streets and homeless. That is the direction we are headed. So while I applaud the opportunity to correct an administrative time crunch there are some really big issues at stake in our community behavioral health world. 

I am fully in agreement to allow a grace period for completing the quarterly review.  Working in an OTP, the development of the treatment Plan (ISP) can be very time consuming, The process of reviewing the treatment plan with the patient, making changes to the treatment plan if necessary and obtaining signatures is not a simple process.  In our population patients can be seen any where from daily to monthly depending on how long they have been in treatment. It is impossible to ensure that the review is completed by the specific date, especially if the patient is not at the program on the deadline.  Writing the treatment plan is also time consuming and counselors have often found there self writing the treatment plan with the patient in the office, which leaves the patients sitting there while the counselor is typing out the treatment plan and is not productive at all for the patient. What normally ends up happening is the treatment plan is brushed over and hurried.   It is a constant juggle between meeting the patients needs and completing the paperwork that is required.  Although not specifically addressed here, I feel compelled to address the DMAS requirement for an IPOC (ISP) on top of the required treatment plan that we currently are required to do, It is tedious and repetitive and adds an extra burden on both the counselor and the patient.  Why are these patients required to have essentially two treatment plans (ISP) because they are on Medicaid. 

I am in favor of the proposed grace periods

Support Coordinators in Hanover are in agreement with the proposed changes.  Many providers provide more than one service to an individual served (community engagement, day support, residential) and have to complete more than one quarterly per person every 90 days. This would allow the provider more time to complete the required documentation.  

Keeping the grace period of 30 days for the Support Coordinator to complete the quarterly is much appreciated. We have a process to track down quarterlies from providers who don't send them in a timely manner and we inform DBHDS Community Resource Consultant of providers who don't send their quarterlies within the time period.

Our only concern would be that even with an extension from 10 to 15 days for the provider, there will continue to be providers who don't send their quarterlies to the Support Coordinator and there is little to no consequence for it. 

AHCS is in favor of the quarterly extensions. 

We are in full agreement with the proposed changes and feel they will benefit CSB's and providers by allowing sufficient time to compile information and complete accurate and comprehensive reviews. 

please just get the CSB case workers/ support coordinators  to do their jobs in a timely manner and stop delaying everything for no reason...  their jobs are not difficult and the amount of paperwork they have to do is min.  (special education teachers for example have much more paperwork in  a similar type of job) …    I wish these gatekeepers weren't even part of the process to access services for people with DD...   how much time do they really need to type a few paragraphs into a program ?  

there is no reason to burden private providers with CSB case workers and MCO program...   it was so much easier and therapy whatever so much more effective when people could just help the person seeking treatment and not jump through all these unneeded extra hoops...   things were so much better before  Medicaid was taken over by all these MCO programs 

We are in agreement with the proposed changes and feel they will benefit CSB's and providers by allowing sufficient time to compile information and complete accurate and comprehensive reviews. 

As a provider, we appreciate this action by DBHDS to ease one of the required documentation processes.

I know one of their group homes run by kemetic behavioral health norfolk va clients is a ward of Jewish Family Services.  they only have one small group home.  It would be interesting to know if Jewish Family Services is doing a poor job of acting as client and not signing documents in timely manner.  It is very sad the way the system works and takes loved ones away from family and friends then takes the consumers small SSI check to pay for guardianship services (at least the rep payee part)  From our understanding a local city is paying them for the rest of the guardianship part.  It is even more upsetting a paid agency is doing a poorer job then a private guardian would be allowed to do.   Maybe that is more of a problem.  Maybe giving agencies more time to deal with government paid guardians isn't the answer; maybe letting people have people who give a crap control their lives would be a better idea.  Isn't that what the Olmstead Settlement was supposed to be about? 

I agree that the grace period should be extended.  With the new CMS requirements, that require time to address, it would be beneficial if providers were afforded the opportunity to have an extended period of time to document reviews or any other regulatory requirement. 

We agree with this extension of the grace period.  We provide services to many individuals that require quarterlies, sometimes one person is working on up to 25 a month on top of other job duties.  Having that extra time will also really help when the 10 days is also decreased by weekend and some holidays.  

Supportive and appreciative of the proposed grace period for quartiles.

I am in support of the grace period for quarterly reviews and the alignment of DBHDS/DMAS Regulations.

In agreement with adding a grace period for Quarterly/Person Centered Reviews.

We are in favor of the proposed grace period for the submission of quarterly reviews.  This will allow for easier scheduling, review of plans and to make any requested changes with regard to the individuals, case management and guardians/family members.  This also provides a cushion in case of an emergency situation due to injury, illness, weather or natural disaster.