1. Chapter IV, pg 9: There is no definition for a Qualified Mental Health Case Manager (QCM) provided. This omission should be corrected.

2. Chapter IV, pg 13: Assessments completed by a qualified mental health case manager may not be used as a Comprehensive Needs Assessment or updated by a LMHP, LMHP-R, LMHP-S, or LMHP-RP to be used as a Comprehensive Needs Assessment.

The proposed guideline should be revised, as it does not recognize the value of assessments completed by QCMs. Given the comprehensive nature of work completed by QCMs, especially in the identification and monitoring of services for individuals, the assessments and reassessments they complete are invaluable in service provision and contain information often unknown an unattainable by Providers with less frequent access/contact. As such, LMHPs and LMHP-types would be more than able to update an assessment or reassessment completed by a QCM to determine medical necessity in the CNA process. The inclusive nature of work done by QCMs would be beyond beneficial, time efficient and aid in effective treatment planning with the LMHP/LMHP-type when evaluating an individual’s need for continued care. This would also allow reciprocal use of assessments completed by QCMs across qualifying programs and DBHDS-licensed providers. The proposed guideline should be reworded to read (or follow as such):

Assessments completed by a qualified mental health case managers may not be used as a Comprehensive Needs Assessment or if updated by completed in conjunction with or under the supervision of an LMHP, LMHP-R, LMHP-S, or LMHP-RP to be used as a Comprehensive Needs Assessment.

3. Along with its ongoing efforts to align regulatory requirements, language, etc., DMAS should work with the DBHDS Office of Licensing to ensure applicable areas of regulation are updated expeditiously to coincide with all pertinent updates/changes (e.g., SSPI = CNA).