We’ve reviewed the proposed chapters in depth and have feedback.

The feedback for Chapter 2 is as follows:

• On page 5 it reads “To participate with one of the DMAS-contracted managed care organizations, they must be credentialed and contracted in the MCO’s network.” In this sentence, who is “they?”
• On page 9, the second to last bullet reads “Accept as payment in full the amount reimbursed by DMAS or its contractor. 42 CFR § 447.15 provides that a ‘State Plan must provide that the Medicaid agency must limit participation in the Medicaid Program to providers who accept, as payment in full, the amount paid by the agency ...’” We would like to know how this applies to copays and patient responsibility regarding medications.
• Additionally, is it permissible to use donated funds for Medicaid members for services that are not covered by Medicaid? Are there any related laws or regulations we should consult?
• On page 11, under ADVERSE OUTCOMES it reads “ARTS providers must notify Magellan of Virginia (BHSA) or the appropriate MCO of member adverse outcomes or critical incidents within one business day following knowledge of the incident.” We are seeking operational definitions of “adverse outcomes” and “critical incidents.” How do you define these terms? Also, there isn’t sufficient clarification on the reporting mechanism. Will there be a portal or a specific point of contact?
• On page 22 it reads “[Providers] must also be qualified by training and experience as defined in the American Society of Addiction Medicine (ASAM) Criteria: Treatment Criteria for Addictive, Substance-Related and Co-occurring Conditions, Third Edition…” Please elaborate on the qualifications and documentation required.
• On page 23 we wanted to discuss changes to several items under the heading “Direct Supervision of Residents and Supervisees”
  • Please clarify the difference in definition of psychotherapy vs counseling services.
  • We are seeking a clear definition of “direct, personal” supervision.
  • We would like for you to reconsider the requirement of a licensed provider signing behind a resident or supervisee. Master’s level residents and supervisees have documented supervision and are trusted to work autonomously. The practice of signing-behind each qualified clinician is time-consuming and can cause billing delays.
• On page 27 there are several references to “Clinical Staff.” Now that the definition of CATP and Allied health professionals have been altered, we would like to have a clear definition of the term “Clinical Staff.”
• On page 27, item 5 indicates “Licensed physicians or physician extenders under supervision of a physician shall perform physical examinations for all individuals who are admitted…” Could this be done with a licensed provider over telehealth when a nurse (or other medical staff) is physically present with a patient in the treatment program?
• We've described our concerns regarding the limitation being placed on the CSAC role and its placement in the category of “Allied Health Professional” in a separate comment as this is a major change that is crippling and problematic in several ways.
• On page 40, there are some typographical concerns in the following sentence: “Collaborative, nonclinical, peer-to-peer services that engage, educate, and support an member’s self-help efforts to improve his health, recovery, resiliency, and wellness to assist members in achieving sustained recovery from the effects of mental illness, addiction or both.” It should say “a member” not “aN member.” In addition, it would be best practice to use non gender-specific language so in place of “his health” we should use “their health.”