Proposed Changes

12VAC30-60-181

Add in CSAC for 3.7-  In 3.7, clients must see physician or extender for physical within 24 hours of admission.  There is already ample oversight by LICENSED STAFF (EVEN MORE IN 3.7)  This will increase availability as licensed staff are  difficult to recruit and not available to work weekends.

12VAC30-60-181

Add in CSAC for 3.7-  In 3.7, clients must see physician or extender for physical within 24 hours of admission.  There is already ample oversight by LICENSED STAFF (EVEN MORE IN 3.7)  This will increase availability as licensed staff are  difficult to recruit and not available to work weekends.

12VAC30-60-181

This section is for an ISP.  A Medication Assisted Treatment assessment does not belong here.  It is not appropriate to have an assessment in an ISP.  ISP is for client goals and must be in client language.  Adding in an assessment here is inappropriate .

The assessment should be in the Assessment/ MDA.  The ISP should reflect needs/goals and preferences as indicated in the assessment.

"Credentialed addiction treatment professionals" professional" or "CATP" means an individual licensed or registered with the appropriate board in the following roles: (i) an addiction-credentialed physician or physician with experience or training in addiction medicine; (ii) physician extenders with experience or training in addiction medicine; (iii) a licensed psychiatrist; (iii) (iv) a licensed clinical psychologist; (iv) (v) a licensed clinical social worker; (v) (vi) a licensed professional counselor; (vi) (vii) a licensed certified psychiatric clinical nurse specialist; (vii) (viii) a licensed psychiatric nurse practitioner; (viii) (ix) a licensed marriage and family therapist; (ix) (x) a licensed substance abuse treatment practitioner; (x) residents (xi) a resident who is under the supervision of a licensed professional counselor (18VAC115-20-10), licensed marriage and family therapist (18VAC115-50-10), or licensed substance abuse treatment practitioner (18VAC115-60-10) and in a residency approved by is registered with the Virginia Board of Counseling; (xi) residents (xii) a resident in psychology who is under supervision of a licensed clinical psychologist and in a residency approved by is registered with the Virginia Board of Psychology (18VAC125-20-10); (xii) supervisees or (xiii) a supervisee in social work who is under the supervision of a licensed clinical social worker approved by and is registered with the Virginia Board of Social Work (18VAC140-20-10); or (xiii) an individual with certification as a substance abuse counselor (CSAC) (18VAC115-30-10) or certification as a substance abuse counseling-assistant (CSAC-A) (18VAC115-30-10) under supervision of licensed provider and within his scope of practice, as described in §§ 54.1-3507.1 and 54.1-3507.2 of the Code of Virginia

Segment above needs to be added back in.  CSACs provide essential services and should be allowed to create a substance related ISP with oversight from licensed staff.  If this is left in, must address that CSACs can  perform ISP’s with oversight.

If  CSACs cannot complete an ISP (with sign off by licensed provider) all  “Primary Counselor” staff  must be licensed.  This would be cost prohibitive.  All BH2s would need to be converted to senior clinicians.  In addition, recruitment would be impossible. Statewide, there is already a shortage of licensed staff.  By adding this requirement, it will make it impossible to recruit and hire  essential staff, thus reducing services available during an opioid crisis. At the very least, allow CSACs with sign off by licensed to complete ISP and MDA assessment in 3.1, 3.3, 3.5, 3.7.  In these setting, there are other credentialed staff on site an available  ensure the client has his/her needs met.

Add in Licensed Nurse Practitioner with experience or training in addiction medicine- Across the State, many nurse practitioners (adult or family) have extensive training and experience in addiction medicine.  They should be included.  

12VAC30-130-5040. Covered services: requirements; limits; standards.

ARTS services require a primary substance use diagnosis, and the purpose for treatment shall be related to the substance use disorder.. A CATP or a CSAC under the supervision of a CATP shall complete the multidimensional assessments. A CATP must sign and date assessments performed by a CSAC within one business day.

Evidence based approaches ( to include David Mee-Lee/chief editor of the ASAM criteria) acknowledge that individuals with co-occurring disorders can have multiple primary disorders.  One is not primary over the other.  Clarify wording to reflect this.  The individual must have a primary substance use disorder, but that does not mean he cannot also have another primary disorder.

12VAC30-130-5050. Covered services: clinic services - opioid treatment program services

Leave it at 12 months versus one year.  12 month is more definitive   

12VAC30-130-5050. Covered services: clinic services - opioid treatment program services

5. Periodic monitoring of unused medication and opened medication wrapper counts when clinically indicated.

Good

12VAC30-130-5050. Covered services: clinic services - opioid treatment program services

9. Women of child-bearing age shall be tested for pregnancy and shall be offered contraceptive services either onsite or through referral.

This says to test.  The individual has the right to choose.  This is too prescriptive.  A test can be offered

12VAC30-130-5140. Covered services: medically monitored intensive inpatient services (adult) and medically monitored high intensity inpatient services (adolescent) (ASAM Level 3.7).

A. Medically monitored intensive inpatient services (adult) and medically monitored high intensity inpatient services (adolescent) (ASAM Level 3.7) settings for services. The facility-based providers provider of ASAM Level 3.7 services shall be licensed by DBHDS as an inpatient psychiatric unit with a DBHDS medical detoxification license, (i) a freestanding psychiatric hospital or inpatient psychiatric unit with a DBHDS medical detoxification license or managed withdrawal license; (ii) a residential crisis stabilization unit with a DBHDS medical detoxification license or managed withdrawal license; (iii) a substance abuse residential treatment services (RTS) for adults/children service for women with children with a DBHDS medical detoxification managed withdrawal license or a residential crisis stabilization unit with DBHDS medical detoxification license; (iv) a Level C (psychiatric residential treatment facility) provider; (v) a "mental health residential-children" provider with a substance abuse residential license and a DBHDS managed withdrawal license; (vi) a "managed withdrawal-medical detox adult residential treatment" provider; or (vii) a "medical detox-chemical dependency unit" for adults and shall be contracted by the BHSA DMAS or its contractor or the MCO. ASAM Level 3.7 providers shall meet the service components and staff requirements in this section.

3.7 has extensive additional requirements to include expensive medical personnel.  Rates for this service need to be reviewed.

12VAC30-130-5140. Covered services: medically monitored intensive inpatient services (adult) and medically monitored high intensity inpatient services (adolescent) (ASAM Level 3.7).

1. Daily clinical services provided by an interdisciplinary team to involve appropriate medical and nursing services, as well as individual, group, and family activity services,  as appropriate  to the needs and current functioning level of the individual. 

It is not clinically appropriate and may often be contraindicated to begin therapy during acute withdrawal.