Pg 5 - CPST Clinical Director has to be available to provide in-person support at the individual's location when clinically needed. 1 person can't possibly be constantly available as needed...vacation, illness, other work responsibilities. Draft manual does not discuss delegation to another LMHP. At every tier, an LMHP is on the team, so it's unclear why another LMHP, who is the CPST Clinical Director, would be needed in person.
Pg. 7- What is the definition/frequency to qualify as “regularly”?
Pg. 7- Some individuals may require more than “minimal” ongoing professional intervention…what is defined as “optimal community integration”?
Pg 8 — It's unclear if the CANS Lifetime is replacing the CNA or in addition to the CNA. If replacing, does it meet Licensing requirements?
Pg 11 — Requires availability of an on-call LMHP 24/7, and unclear whether this can be provided by a properly credentialed staff in another area of the organization (i.e. ES Clinician) or must be part of the CPST Team.
Does a DBHDS Licensed facility (residential location or clubhouse “count” as an office) for the three hour limit?
Pg 12 — Has a copy of the CANS Lifetime been provided yet to be able to assess/review the tool?
Pg 12 — If a CANS Lifetime has been completed by another DMAS provider in the previous 12 months it must be used, but Licensing requires an initial and comprehensive CNA upon admission to a service. So this is either an additional assessment or won't meet Licensing regulation.
Pg 14- Documenting each EBP protocol within ISP-New expectation to document each EBP Protocol seems to add additional burden that does not directly contribute to benefit the client.
Pg 14- Documenting/updating each EBP protocol every quarterly. Same as comment above. Would require changes to quarterly.
Pg 14-Does the face to face review requirement every 90 days mean a full team meeting, or just a review with the client and direct staff which can be signed off on by the LMHP?
Pg 15- D. Is this meant to mean the CPST provider agency? Or are they requiring their specific provider/team?
Pg 17- Adds requirement to contact MCO every time the individual accesses the crisis continuum. Shouldn't this information be available to MCO through VCC or claims information?
Pg 18 - Care coordination should be able to be provided by qualified mental health case managers who do not need to be QMHPs. Care coordination by a CPST team member is duplicative of what an MHCM can do and does.
Pg. 20- Documentation around why standalone EBPs not available/not appropriate is burdensome as well as the requirement to coordinate with the MCOs as required referrals to standalone EBP.
Pg 21 — No other service is required to report DBHDS CAPs to MCOs.
Pg. 29- : If an individual has remained at the same Level of Need for 18 calendar months without improvement, the provider shall notify the individual's MCO and, in coordination with the MCO, develop a plan to refer the individual to an appropriate evidence-based practice, as set forth in Section 3.2 and Section 8.6 (Continued Stay Criteria). Documentation of this referral process shall be maintained in the individual's record, and the ISP shall be updated to reflect the plan.- This wording makes it seem like the individual has no choice in their services changing. What if the individual doesn’t want to be referred elsewhere? What is the plan for if an individual declines to accept new services? Is the intention to discharge them regardless of them finding alternative services?
Pg 34- MCOs can either approve authorization or recommend a more clinically appropriate service- If we follow the extensive process outlined above and develop recommendations/establish eligibility in a person-centered way with a team of professionals, it seems unreasonable and inconsistent with requiring heavy involvement of LMHPs that the MCO would serve as the surrogate clinical decision maker.
Pg 36 requires an LMHP to write a progress note in the individual's chart every 30 calendar days to document review of documentation OR co-sign every progress note of anyone less than an LMHP - This seems impractical use of highly qualified staff.
Pg 40 requires all LMHP/LMHP-Types providing CPST Youth services to be credentialed in Managing and Adapting Practice (MAP) w/in 18 months of the agency's enrollment w/ DMAS for specialty 925. New hires have 18 mos as well. Credentialing requires curriculum training, 6 months of consultation, and a portfolio review. More training is described on pg 41 provided through DBHDS Learning Management System that must be completed w/in 12 calendar months of enrollment or new hire. - This is extensive training for highly credentialed staff.
Pg 41- Required to have DBHDS BHT academy training- Should this be required or could the credential established by DHP for BHTs rather than limiting to only one of the options available? This will restrict the workforce available.
Pg 41- Requiring submitting this in both DBHDS LMS and to CEP-VA is overly burdensome, especially when most providers maintain their own robust LMS systems. Would DMAS consider requiring providers to provide this documentation at time of audit?
Pg 45- Supervision expectations for LMHP-E, QMHPs, and BHTs still are overly burdensome, especially for the L’s and the Q’s
PG 46-47- Caseload matrices, limits, and composition is restrictive, and remain a huge increase in admin overhead.
