CSC Appendix

#1         #3.2 - Pick a name for the “CANS” and use it consistently

#2         Add “if appropriate” at the end of #2 & #7.a. & #8 (following “natural supports”

#3         Are reviews “every 90 days” or “quarterly” (pick one)

#4         How does any ISP “assure individual/family/caregiver involvement? [#8.a.iii]

#5         Is “psychotherapy” the only approach?  Is it required?

#6         #3.8.2.a. implies that there is a “team” sitting on a bench waiting for a call – the wording needs to reflect something less than that and if the preferred method is for the individual to use 988, then how will 988 connect with the appropriate staff?

#7         #3.8.#7 appears to contradict the second paragraph under 3.8

#8         #4.1 in paragraph #2 – “CSC teams shall operate from a single office location” – define exactly what that means – considering that some services can be provided via telehealth, and some in person where the individual lives/works; what tasks are to be done in a specific office?

#9         #4.1.1 -- “and attend at least 3 out of 4 weekly” a caveat needs to be added about being on “approved leave” – particularly in light of HB5/SB199 in the 2026 Session!

#10       #4.1.1 #1 – I do not believe there is a Virginia Code definition of “full-time” – and simplify the language (remove the repetitive “LMHP Team Leader”)

#11       Having the Psychiatric Provider attend weekly meetings will be both challenging and costly & for #4.1.1 #4 – define the “training” required

#12       Define the “Medicaid qualifications for CSC reimbursement” for each of the roles listed.

#13       How accessible is the training required, how expensive, how much time does it take, etc.

#14       #4.2.2 - Exclude from clinical supervision the psychiatric provider and include and explanation of who supervises the Team Leader.

#15       #4.5 change the parenthetical to be “conditional or full – annual or triennial)

#16       How is the “fidelity monitoring” done, what frequency, by whom?

#17       #5.1.1 – See comment # 1

#18       “All of the following criteria (a-c) and the listing is numeric

#19       #5.2.2.a – Medication is managed in accordance with an ISP, but in accordance with prescriber’s orders

#20       Section 6 #6.a.  This appears to eliminate the role and collaboration of the CSB/BHA – why?

#21       #7.2 can not be assessed without a rate sheet and better description of a “unit”

#22       #7.2.3 How will “minimum service” units be enforced?

#23       #9.4     H0031 is currently used in Intensive In-Home – as the intent is to have services “overlap” this code will need to be changed.