The feedback for Chapter 6 is as follows:

• Page 11 reference reports regarding Provider fraud, however it is unclear if reports need to go to the MCOs in addition to Magellan as the language currently reads “Reports may be made to Magellan of Virginia via one of the following methods…”
• Page 12 reviews Member Fraud. If providers make every effort to confirm membership of an individual and do their due diligence, and member fraud is still found to have occurred, does this mean payment for services for this individual will be detracted?
• On page 17 it reads “Checklists and boilerplate or repeated language are not appropriate.” We ask that this be reconsidered in the event patients receive a large group lecture, or psychoeducational seminar as documentation is generally a brief summary of what was presented and an indication of participation level.
• On page 23 under the heading DOCUMENTATION REQUIREMENTS FOR ARTS it reads “Providers must use the Addiction and Recovery Treatment Services (ARTS) Service Authorization Extension Review Form for extension requests for the same ASAM level as the MCOs and the BHSA have agreed to utilize this one form for ARTS service authorization extension requests.” Not all of the MCOs use the ARTS Service Authorization Review Form. Will they be required to use it going forward?
• Page 25 reads “The multidimensional assessment documentation shall support an individualized, person-centered biopsychosocial assessment performed face-to-face…” Will the option to perform multidimensional assessments via telehealth no longer be available after the state of emergency ceases?
• Page 26 and 27 contain information about the Multidimensional Assessment Provider Requirements. We will further discuss our concerns about the limitations placed on CSAC and CSAC Supervisees in a different comment. Regardless we would like the language reflected in 3.5 Re: CSACs to be reflected for all levels of care and include at least CSAC Supervisees.
• On page 29 there is a typographical error in the final bullet, “ISP (s) should be reviewed on a consist basis to ensure treatment goals are being meet and are still applicable to the individual treatment needs of the member.” It should say “CONSISTENT basis.”
• On page 30, under the heading Individual Service Plan (ISP) Provider Requirements for Level 4.0 it appears the Licensed Substance Abuse Treatment Practitioner (LSATP) is missing. Was this done purposefully? We believe the LSATP needs to be explicitly identified among the list of appropriately credentialed clinical staff.