Commenter:
Susan Bergmann, LCSW, MBA - Director of QI at NCTR
ARTS Manual Chapter IV - Questions, Comments, Concerns
The feedback for Chapter 4 is as follows:
Page 10 contains the definition of Allied Health Professional which excludes a person who is a supervisee working toward their CSAC experiential hours. Can this be added to the definition (at the very least)?
We will further discuss our concerns about the placement of CSAC and CSAC Supervisees within this category in a different comment.
Page 18 contains the definition of Opioid Treatment Services which references “Preferred Office-Based Opioid Treatment (OBOT).” Should this be changed to reflect the new name of this service, “OBAT”?
Page 23 contains the definition of Telemedicine which exclusively includes “the use of audio and video equipment.” Can a stipulation be added to this that in the event of a technical emergency (utility failure, internet outage, etc.) audio-only services will be accepted?
Item 2 under MEDICAL NECESSITY CRITERIA on page 25 states that “The member shall be assessed by a CATP, as defined in 12VAC30-130-5020, acting within the scope of their practice…” According to the new definitions, this would exclude CSACs, CSAC Supervisees, and CSAC-As from completing assessments, however, page 38 reads “ARTS Services (as defined in 12VAC30-130-5000 et al) shall meet medical necessity criteria based upon the … multidimensional assessment completed by a CATP or CSAC/CSAC-Supervisee.” These appear to contradict one another, or at the very least, indicate a need for clearer language when referencing “assessments” as a whole. Can a CSAC, CSAC Supervisee, and/or CSAC-A complete a multidimensional biopsychosocial assessment at all levels of care?
Furthermore, page 37 and page 38 reference “Clinical Assessment” as distinct from “Multidimensional Assessment.” However, on page 57 it reads “Clinical assessments by the treatment team shall encompass factual, biopsychosocial data;” which overlaps with the definition of a Multidimensional Assessment. We need a clearer understanding of the terms Clinical Assessment and Multidimensional Assessment – how they differ, and who can conduct them.
Page 26 contains a definition of screening, but does not clearly indicate who can and cannot complete screenings. Can screenings be done by Allied Health Professionals?
On page29 under Discharge Planning within the ISP, there is a typographical error. The sentence reads “Discharges shall also be warranted when one of the below criteria is meet:” when it should say “is MET.”
On page 38, we are wondering why a CATP or CSAC can complete progress notes, but a CSAC Supervisee or CSAC-A cannot do this at the residential levels of care (3.1 – 3.7).
On page 44, it reads “Preferred OBAT services are allowable in ASAM Levels 1.0 through 3.7 excluding inpatient services.” Since level 3.7 is inherently inpatient, why are they included in this statement? In what ways can OBAT services be allowable at the Residential levels?
On page 55, the second to last bullet states “Time not spent in skilled, clinically intensive treatment is not billable.” We are looking for an operational definition of “skilled, clinically intensive treatment. For example, if yoga group is provided at the PHP/IOP/OP levels of care as a mindfulness, stress reduction, or coping skills group, would this be considered “skilled, clinically intensive treatment”?
On page 58, the final bullet reads “Clinically directed program activities by CATPs, constituting at least five hours per week of professionally directed treatment…” What is the difference in definition of clinically versus professionally directed treatment? Can a CSAC, CSAC Supervisee, or CSAC-A provide professionally directed treatment?
On page 60, the third bullet reads “Medication education and management shall be provided.” This should include the same caveat as the preceding two bullets on page 60. We suggest adding the phrasing “Such services are provided either on-site or closely coordinated with an off-site provider.”
On page 69, we suggest the inclusion of CSAC-As in the statement “Group substance use counseling by CATPs, CSACs and CSAC supervisees shall have a maximum of 12…”
On page 73, the first bullet indicates that the MCOs and the BHSA now have “72 hours” to respond to the service authorization request. Does this mean that providers now have expanded time to submit service auth requests (especially considering that patients at 3.7 LOC are likely impaired upon initial assessment)?
