|Action||2011 Mental Health Services Program Changes for Appropriate Utilization & Provider Qualifications|
|Comment Period||Ends 1/29/2015|
Re: Proposed changes to IIH regulations
I very much concur with Andrew K. Slabaugh, LCSW and Kathy Levenston, LCSW. Having care cordination being limited to only medical providers will stall treatment for individuals receiving these services since more time and resources would have to be diverted towards coordinating with other providers and waiting for outcomes. This will also further inundate Community Service Boards who are already under stress providing for their current client case loads. In additon, several agencies have a "wrap-around" or "holistic" approach to mental health treatment which would encompass case managment activities. Stymying agencies from case management activites will result in reduced quality care for clients. IIH providers must be able to continue with providing case management services. On a side note, some CSBs have policies to not share their treatment notes (whether it be for case management services, psychiatric progress notes, etc.) with other agencies involved in the client's care. Again, this will result in further delays and less efficient care.
I also agree that having to justify the location of an IIH session provides a documentation burden for providers. In order to establish privacy and ensure appropriate confidentiality sessions may have to be relocated to a different setting that may not directly relate to an "identified need" other than the implicit need/right to privacy and safety.
I share the concerns about the proposed documentation requirement of all previous interventions. This creates an additional burden not only to the providers but also the caretakers of the potential client. I agree in trying to obtain as much documentation as possible of previous interventions for the client's chart in order to better determine necessarily revisions of a treatment plan. However, requiring this information up front before services can take place will cause delays potentially resulting in avoidable crises.