Loudoun MHSADS agrees with and supports all comments to date. 

Definitions:

Definition for ACT describes the provider being the primary provider for ALL services. As ACT is not the provider for all medical (e.g., eye, dental, physical) we recommend removing "all" from the definition. 

Definition for ICT no longer is consistent with new criteria within the regulations. 

12VAC35-105-1360 Admission and discharge criteria

Will the admission criteria be consistent with DMAS criteria? 

Discharge

There are also times when the individual disengages and ICT or ACT staff do not know where the individual is, so revising the ISP is n/a if the person is not located.

What is the evidence-based decision for two years? This seems paternalistic in the absence of data indicating two years as the recovery mark. Plus if you add #5 under the heading in B (“discharged for failure to comply or other expectations”), it seems that sustained recovery is considered a failure.  Recommend either remove five or change the header in B.

12VAC35-105-1370 Treatment team and staffing plan

Recommend inserting some language allowing CSBs to hire the most qualified applicant for each position even if the qualifications fall short of licensure requirements if no applicants meet the qualifications set forth in licensure. There is a shortage of professionals especially with this many years of required experience.

For ICT and ACT staffing ratios: we cannot discharge individuals for two years of sustained recovery with minimal contacts, or inpatient treatment for over a year, or incarceration for a year (which means we would have someone being counted as a client who is not receiving the intensive levels of service). Recommend language that allows for additional individuals to be enrolled per individual in monitoring or transitioning status.

Peer Specialists who are certified or become certified within a year of employment as a Peer Specialist. REcommend removing reference to QPPMH or QMHP. Keep this consistent with ACT Peer Specialist. Also, remove the description of what type of mental illness is required for the peer recipient of services for “Severe and Persistent” mental illness.

Recommend LMHP-E anywhere it says LMHP

Recommend ICT and ACT allow a physician and/or advance practice nurse working within the scope of the medical training and license to provide psychiatric medication services.

"2. The team shall be the first-line crisis evaluator and responder for individuals served by the team if clinically appropriate." It would not make sense clinically to make an individual in need of a TDO talk to an ACT therapist first and then repeat the whole evaluation with Emergency Services.