Thank you for providing us with the opportunity to make comments and to seek clarification of the proposed Mental Health Case Management changes.
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Guidance Category |
Draft Language |
Comments |
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Section 1. Definitions |
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No comment |
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Section 2. Mental Health Case Management (H0023) |
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No comment |
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2.1 Population Definitions |
No comment |
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2.1.1 Serious Mental Illness |
No comment |
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2.1.2 Serious Emotional Disturbance |
No comment |
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2.1.3 At Risk of Serious Emotional Disturbance |
No comment |
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2.2 MHCM Service Definition |
No comment |
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2.3 Required Activities |
No comment |
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2.3.1 Case Management Engagement |
We respectfully request reconsideration of the requirement that one of the two required face-to-face case management services be delivered exclusively in community?based settings outside the CSB. While community?based engagement is often beneficial, this mandate does not fully account for the diverse needs, preferences, and safety considerations of the individuals served. For some individuals — including those experiencing homelessness, living in shared or unstable environments, or facing safety concerns — the CSB may represent the most private, secure, and clinically appropriate location for service delivery. Additionally, some individuals may decline home? or community?based meetings due to privacy needs, stigma concerns, or personal comfort. Staff safety considerations may also limit the feasibility of community visits. |
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2.3.2 Assessment |
Further clarification is requested regarding the requirement that providers coordinate the review of the Individual Service Plan (ISP) with the case manager. Specifically, clarification is needed as to whether this requirement applies exclusively to non?CSB providers or to all service providers. |
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2.3.3 Service/Supports Planning and Monitoring |
No comment |
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2.3.4 Case Management with Service Providers |
No comment |
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2.4 MHCM Medical Necessity Criteria |
No comment |
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2.4.1 Admission Criteria, Diagnosis, Symptoms, and Functional Impairment |
No comment |
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2.4.2 Continued Stay Criteria |
The continued stay criteria does not sufficiently acknowledge the critical role that stability plays in the lives of individuals living with serious mental illness, as well as the corresponding impact on their families and the broader community. Case management services are fundamental in supporting, maintaining, and enhancing this stability over time. We respectfully request reconsideration of the requirement that measurable progress be demonstrated as a condition for continued case management services. For many individuals, the maintenance of stability itself represents a significant and clinically meaningful outcome that warrants ongoing support. |
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2.4.3 Discharge Criteria |
No comment |
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2.4.4 Exclusions and Service Limitations |
No comment |
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2.5 MHCM Provider Participation Requirements |
No comment |
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2.5.1 Provider Qualifications |
No comment |
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2.5.2 Staff Qualification Requirements |
No comment |
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2.5.3 Staff Caseload Requirements |
We encourage consideration of additional flexibility within caseload requirements to ensure case managers can effectively support individuals with varying levels of need. Flexibility is essential for maintaining service quality and supporting person?centered, responsive care. |
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2.6 MHCM Service Authorization and Utilization Review |
No comment |
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2.6.1 Service Authorization |
No comment |
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2.6.2 Documentation and Utilization Review |
No comment |
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2.7 MHCM Billing Requirements |
No comment |