Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
Action Allowing a grace period for documentation of ISPs
Stage Proposed
Comment Period Ended on 3/20/2020
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1/23/20  8:21 am
Commenter: Sellati & Co., Inc

Extension of time
 

I am fully in agreement to allow a grace period for completing the quarterly review.  Working in an OTP, the development of the treatment Plan (ISP) can be very time consuming, The process of reviewing the treatment plan with the patient, making changes to the treatment plan if necessary and obtaining signatures is not a simple process.  In our population patients can be seen any where from daily to monthly depending on how long they have been in treatment. It is impossible to ensure that the review is completed by the specific date, especially if the patient is not at the program on the deadline.  Writing the treatment plan is also time consuming and counselors have often found there self writing the treatment plan with the patient in the office, which leaves the patients sitting there while the counselor is typing out the treatment plan and is not productive at all for the patient. What normally ends up happening is the treatment plan is brushed over and hurried.   It is a constant juggle between meeting the patients needs and completing the paperwork that is required.  Although not specifically addressed here, I feel compelled to address the DMAS requirement for an IPOC (ISP) on top of the required treatment plan that we currently are required to do, It is tedious and repetitive and adds an extra burden on both the counselor and the patient.  Why are these patients required to have essentially two treatment plans (ISP) because they are on Medicaid. 

CommentID: 78900