1. CSAC versus CATP

Confused about the multiple references differentiating CSACs from CATPs (Credentialed Addiction Treatment Professionals).  We have been operating all of the time with the understanding that a CSAC is a CATP based on the definition given below in the initial ARTS rollout:

[1] “Credentialed Addiction Treatment Professionals” include licensed clinical psychologists, licensed clinical social workers, licensed professional counselors, licensed psychiatric clinical nurse specialists, licensed psychiatric nurse practitioners, licensed marriage and family therapists, licensed substance abuse treatment practitioners,  licensed substance abuse treatment practitioners, or individuals with certification as a substance abuse counselors (CSAC) who are under the direct supervision of one of the licensed practitioners listed above.

               Recommendation: references should be for CATPS only, in other words, CSAC should not be differentiated from CATPs in the document

2. Face to face definition:

"Face-to-face" means encounters that occur in person or through telemedicine.

“Individual psychotherapy or substance use disorder counseling between the individual and the provider shall be provided by a credentialed addiction treatment professional/CATP. Services shall be provided face to face in person or by telemedicine”

"Telemedicine" means the practice of the medical arts via electronic means rather

than face-to-face the real-time, two-way transfer of medical data and information

using an interactive audio-video connection for the purposes of medical diagnosis

and treatment. The member is located at the originating site, while the provider

renders services from a remote location via the audio-video connection.

Equipment utilized for telemedicine shall be of sufficient audio quality and visual

clarity as to be functionally equivalent to a face-to-face encounter for professional

medical services.”

Recommend: Resolve inconsistencies in the above definitions.

1. Change “telemedicine” to “telehealth” language throughout. Or, change to “video telehealth”. Telemedicine is older language that excludes things such as counseling by most definitions, including the one in the draft by referencing “medical”
2. Highly recommend deleting the line about originating site. This would allow for members to join services from their homes, versus having to come in the clinic due to transportation or childcare barriers. This has proven to recently help with retention and engage rates.  Or, Add a client’s home as a viable remote origination site for telehealth.
3. Highly recommend allowing group counseling options via telehealth.  COVID-19 experiences have resulted in significant increased engagement and is ideal for some who have barriers to treatment such as transportation or childcare.

3. ISP requirements for CSACs:

“All ISPs shall be completed and contemporaneously signed and dated by the credentialed addiction treatment professional CATP preparing the ISP. For ASAM Levels 3.1, 3.3, and 3.5, the ISP may be completed by a CSAC if the CATP signs and dates the ISP within one business day.”

Recommendation:

A) CSACs should be able to prepare ISPs at level 2.1 and 2.5 as well as others listed.

 B) CSACs that meet CATP definition should not need to be signed off by others! Currently, CSACs complete their own ISPs without additional approval signatures. Having a licensed person have to sign all ISPs would create a lot of additional work for the licensed staff and add to the already large amount of documentation and review needed to admissions. The Code of Virginia § 54.1-3507.1 indicates that CSACs are “qualified to be responsible for client care of persons with a primary diagnosis of substance abuse or dependence. Providing counseling to persons for a mental health diagnosis other than substance abuse or dependency is outside the scope of practice for CSACs.”

4. Use of telemedicine for ASAM 2.1 and 2.5

“Reimbursement for substance use outpatient services shall be made for medically necessary services provided in accordance with an ISP or the treatment plan and include withdrawal management as necessary. Services can be provided face-to-face in person or by telemedicine. Outpatient services shall meet the ASAM Level 1.0 service components and staff requirements as follows:”

Recommendation: In addition to the OBOT, psychiatric, medical and ASAM 1.0 levels of care;   

expand access to care by including ASAM levels 2.1 and 2.5 levels of care in the provision of in person or telemedicine services.

5. ISP revision timelines

”The provider shall include the individual and the family or caregiver, as may be appropriate, in the development of the ISP or treatment plan. To the extent that the individual's condition requires assistance for participation, assistance shall be provided. The ISP shall be updated at least annually and as the individual's needs and progress change. An ISP that is not updated either annually or as the individual's needs and progress change shall be considered outdated.

Recommendation: Clarify and require that the ISP be reviewed quarterly, every 90 calendar days, and updated as the member's progress and needs change to recommend changes in the plan as indicated by the member's overall adjustment during the placement.

Recommendation:  For OBOT treatment, discontinue required monthly ISP reviews and continue Quarterly reviews as is congruent with the standard for substance use treatment.

Support the increased references to telehealth options