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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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4/19/26  2:02 pm
Commenter: Fairfax-Falls Church Community Services Board

Comments on the Revised Draft of CSC
 

Section 7.2.3 requires individuals to receive no fewer than 24 consecutive months of service, raising a major concern because not all individuals need a full two years in the program, and this requirement may conflict with person-centered care; allowing discharge based on clinical readiness would better align with individualized treatment. Section 3.8 identifies the CSC provider as a primary crisis contact in the individual’s crisis plan, which is clinically appropriate but may conflict with real-world practices in which individuals access 988, emergency rooms, or CSB emergency services; this could be reframed to emphasize coordination rather than primary responsibility in all situations. Section 9.2 requires at least four in-person encounters per calendar month, which may not reflect client preferences, the effectiveness of telehealth, or the operational realities for CSBs serving rural or geographically dispersed populations; increased flexibility for telehealth when clinically appropriate would better support engagement and retention.

 

CommentID: 240488