Definition section:

“ a team of medical, behavioral health , and rehabilitations professionals….”

Comment—seems like we could just say a team of behavioral health professionals..

“to meet the needs of an individuals with severe and persistent…

1. “Provide person-centered services addressing the breadth of an individual’s needs, helping him the individual achieve his personal identified goals.”
2. “serve as the primary provider of all the behavioral health services that an individual …..

10.  “promote self-determination, respect for…, and engage peers in promoting recovery….

Comment—does this use of “peers” refer to the individual being served, Peer Recovery Specialists, other professionals…?

Treatment team and staffing plan:

1d.  QPPMH or QMHP-A—the language from the Department of Health Professions is “Registered Peer Recovery Specialist”. It would be helpful to use the same language.

4b. Nurses—ACT nurses shall be full-time employees or contractors….

Comment:  Does this exclude the use of permanent part-time nursing staff?  The requirement that medium and large ACT teams can only hire full-time nurses limits flexibility in a very competitive job market for nurses. 

4f. Program Assistant—"one full time…”

Comment: Is this indicating that even a small ACT team would need a full-time program assistant? This standard is also very specific about job functions.  In large boards some of these functions like “maintain accounts and budget records” are farmed out to other parts of the agency—not totally sure what “budget records” is referring to.

4g. Psychiatric Care Provider: “…The psychiatric care provider shall be a fully integrated team member who attends team meetings and actively participates in developing and implementing each ISP.” 

Comment:  regulations like this often prompt licensure specialists to ask how we can document the psychiatric care provider’s development and implementation of each ISP?  Would this require the Psychiatric Care Provider’s signature on the ISP?

5.  Staff to individual ratios for ACT Teams:

There is labeling error in this section—it goes from a,b,c, to B, C, D

D-E.  5D states that an ACT team may arrange coverage through another crisis services provider. 5E 1-2 indicates that the “team shall be available to individuals in crisis 24 hours per day…” and “the team shall be the first-line crisis evaluator….”  Section D and E seem to be in conflict with each other.

Contacts:

 Section A.  –It is unclear how  the aggregate average will be determined.  Will this be based on one week randomly selected by the licensure specialist, a span of time, etc?  This appears to be more of a fidelity measure than a licensure regulation. 

ICT and ACT service daily operation and progress notes:

Section A indicates that ICT and ACT teams “shall conduct daily organizational meetings Monday through Friday…”  Section 5B indicates that teams “shall meet daily Monday through Friday or at least four days per week…”  These two sections are in conflict with one another.

Service requirements

11.  “which shall be directed exclusively to the well-being and benefit of the individual…”  This requirement seems unnecessary and very subjective. For example, if we are teaching parents appropriate limit setting skills, the individual being served may not think this is beneficial.