Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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10/22/25  4:19 pm
Commenter: Mindy Carlin, Virginia Association of Community-Based Providers (VACBP)

Comments on Definitions
 

The following summarizes feedback regarding the "Definitions" section received from our members since the draft policy was released:

  • CANS Lifetime Assessment Clarity: Need explicit guidance on which evidence-based practices (EBPs) are required or allowed; uncertainty over whether providers can use alternative EBPs.
  • Terminology and Compliance Ambiguity: Terms like “affiliated” and “school setting” are unclear, as are expectations for MOUs and their alignment with FERPA/HIPAA.
  • Supervision Standards: Request clarification on what it means to “address the spiritual needs” of individuals within supervision requirements.
  • Tele-Supervision and Confidentiality: Recommend updating “face-to-face” and “supervision” definitions to reflect modern tele-supervision practices while ensuring confidentiality safeguards.
  • Transparency on CANS Lifetime Tool: Stakeholders want to see the actual CANS Lifetime tool and question why it hasn’t been shared publicly.
CommentID: 237492