7.4        It appears that the planned “methodology” for documenting staff qualifications (i.e., completion of the “required training”) is to require that providers “submit information pertaining to the qualification of each staff person providing CPST to an external entity (CEBP at VCU) and keep information “current and active.”   In addition to maintaining internally a record of staff qualifications and training for examination by DBHDS Office of Licensure and submitting, as required, the same information to all of the contracted MCOs for the purpose of supporting the billing/credentialing as needed,  this appears to be either duplicative (and therefore and uncompensated cost for providers), or an attempt to add an additional layer in an attempt to compensate for systemic failure of the existing system of oversight to be effective. 

              If the service is provided by a staff member who is qualified, the fact the an external entity does or does not have their name on a list is irrelevant. 

              Adding a requirement (which will also require monitoring by an entity with authority to do so) will not make a material difference for any provider inclined to skirt the edges of the rules, but will add an additional burden for all providers who make every attempt to comply.  How will you know, and how will you monitor, and what are the consequences for non-compliance?