In Chapter IV the therapeutic pass guidelines note that the pass is approved by the treating physician.  It seems more in line to have a licensed person approve the pass as they are the people responsible for the weekly assessments of the youth and are likely interacting with the family more.  This person has a better sense of the family dynamics, pass implications for treatment, and specific goals for the passes.  Having the treating physician sign this as an approval could add a burden for facilities who contract out for psychiatry.  

In the Draft in Chapter IV on page 15 it notes on site nursing and then on page 22 it notes nursing availability.  In the past, it has been nursing availability.  Will that remain?  Having on site 24/7 nursing had not been part of the previous regulations for PRTF.  

Chapter IV

Page 5 & 10  Can you provide more details regarding the expectations of ADL & Skills Restoration to include frequency and relation to the current psychoeducational group requirement?

Page 26  Does the SSPI satisfy the requirement for #1 under TGH Requirements?

Page 26  Does the IACCT LMHP complete the face-to-face evaluation for #2 under TGH requirements?  Also, what would this look like for emergency admissions?

Chapter VI

Page 9  Progress Notes--Will be be required to include times on progress notes for TGH despite the services being billed based on a daily rate?

Appendix D  

Page 10  CON required signatures--In the event of emergency placements, is a licensed physician/clinical psychologist signature required on the CON?