Include in service definition: Outpatient services shall not include practitioners who hold a license issued by a health regulatory board of the Department of Health Professions or who are exempt from licensing pursuant to 54.1-2901, 54.1-3001, 54.13501, 54.1-3601 and 54.1-3701 of the code of Virginia.
Remove general health care from SA OP (H). General health care is outside the scope of practice for a therapist.
12VAC35-109-40 A.2 g. Screenings should capture basic information about the person's risk, medication ,etc. Remove "including recent increase, decrease, discontinuation, etc.
12VAC35-109-50: Remove and possibly add to 109-40 all screening information shall be reviewed and updated as appropriate at the time of initial evaluation.
12VAC35-109-110- recommend removing #2. as it limits who can provide direct supervision in many programs to license or license eligible persons as guidelines says can approve assessments and ISPs.
L1. expand to include General Physicians and Physician Extenders
M3. remove provide and replace with coordinate with .........
12VAC35-109-200 E. Recommend that the entire section E ,aligns with Federal Guideline for OTP and addendums to include the removal of :RN, program sponsor needing license or certified, regulating percentages of licensed, certified counselors, required security personal, etc.
F. ( not clear as to the meaning or intent)
G ( remove change or loss of staff requires written notification and plan). Federal OTP guideline indicates the minimal staffing pattern.
H ( remove)
H4 ( remove caseload size for license and non licensed counselors). Caseloads are determined by multiple factors to include but not limited to : client's level of intensity, centralized services, type of service -primary, follow-up, etc., client's time in treatment, etc.
12 VAC35-109-280 A. remove 1 hour minimum.
A1. Remove every week for the first 6 months. Replace with Federal OTP guidelines ( twice monthly) first year. Second year at least once monthly.
12VAC35-109-290 #2 remove weekly random drug screen- replace with Federal OTP guideline 8 per year and when clinically necessary
12VAC35-109-400 #3-Revised to say ensure clients have appropriate contact crisis information outside of clinic's normal hours.
12VAC35-1090-440 services #4, 5,6 appears to be case management and care coordination functions.
