4 comments
Thank you for giving me the opportunity to comment on the Draft Case Management Chapter Regulations for DBHDS. Below you will find my comments and recommendations.
12VAC35-110-10
Thank you for defining legal guardian and comprehensive assessment. We recommend adding a definition for enhanced case management.
12VAC35-110-30
Recommend a wording change in the first sentence. We would prefer the sentence to say “Case management services are designed as applicable to assist” rather than “Case management services shall be designed”. I also recommend that ID/DD and MH/SUD Case Management be separated as they each provide unique services to their client.
12VAC35-110-40
Recommend removal of the word “knowing” from number 11 as the Case Manager may not always know medical information as it may not be shared or disclosed by the individual.
12VAC35-110-50
Recommend changing letter g Medical Symptoms to Medical Conditions.
12VAC35-110-70
This section specifically states that the provider shall be actively involved through face-to-face contact. Could part of these contact be made through telehealth?
12VAC35-110-80
Section C(2) states that the provider shall distribute the ISP to the individual and others authorized to receive it prior to the implementation of the ISP. The ISP meeting may be out in the community which would make it difficult for the case manager to distribute. Recommend removing the statement “prior to the implementation of the ISP” to give case managers time to distribute the ISP instead it could state a timeframe or by the next scheduled service.
Section F states that when a case management agency provides more than one service to an individual the agency may maintain a single document however sections A and B states that a case manager shall complete a distinct, separate, initial case management ISP. Please clarify the requirements as these sections contradict each other.
Section I is confusing as it does not define what readily accessible means. Please define readily accessible. If the case manager must bring a printed copy of the ISP we have concerns with protecting that information during transport as it is not HIPAA compliant to take paper copies out in the community. Also, it is not environmentally conscious to print ISPs that take up multiple pieces of paper. If the case manager could have electronic access that may be safer and more HIPAA compliant however there would be a cost to the CSB in purchasing the needed equipment to ensure the information is accessible.
12VAC35-110-90
Section G is confusing as it does not define what readily accessible means. Please define readily accessible. If the case manager must bring a printed copy of the ISP we have concerns with protecting that information during transport as it is not HIPAA compliant to take paper copies out in the community. Also, it is not environmentally conscious to print ISPs that take up multiple pieces of paper. If the case manager could have electronic access that may be safer and more HIPAA compliant however there would be a cost to the CSB in purchasing the needed equipment to ensure the information is accessible.
12VAC35-110-110
If this section pertains to ID/DD services only this need to be stated. Please clarify.
12VAC35-110-120
For sections A.1, 5, 6, 7, 8 please replace ensure with facilitate or coordinate. Section A is not person-centered as it is not giving the individual a choice in their health care. Recommend adding a statement on client choice.
12VAC35-110-130
Please provide guidance on how to demonstrate and capture the listed competencies. I feel that maintaining this documentation in our personnel records would cause an additional administrative burden on our administrative departments.
12 VAC35-110-89. ISP Requirements:
In Section A, it references an initial ISP. Please consider revising language to include if the comprehensive ISP is completed an initial ISP is not required. Requiring an initial ISP separate from a comprehensive ISP can be burdensome to client and provider if this is not necessary.
12VAC35-110, Enhanced Case Management Contacts:
Please consider taking out requiring a visit in the individual's home and leaving meeting with the individual face-to-face at least every 30 days.
Thank you for considering these comments.
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12VAC35-110-80. ISP requirements.
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D. This puts the case manager responsible for other provider's implementation. Disagree with this statement. The Case Manager is responsible for determining the individual's satisfaction with services, needs for additional services and assisting with problem solving issues.
E. Concern about use of "detailed" here---there is an overarching push to have detailed individualized protocols for everything---while the service practices can address overarching health and safety concerns.
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12VAC35-110-90. Reassessments and ISP reviews.
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E. Must include documentation of the review will be in the file within 30 days after the end of the quarter to allow time for case manager to receive and review other provider's quarterly reports, which must be completed 15 days after the end of the quarter. |
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12VAC35-110-110. Enhanced case management contacts.
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The way this is written it would apply to all types of case management, not just DD/ID. This is problematic..
If an individual has lived in the setting for more than a year, then this criteria should not apply with regard to training center transition and congregate care setting as a reason to have ECM.. |
12VAC35-110-10 - thank you for defining legal guardian and comprehensive assessment. Recommend adding a definition for enhanced case management
12VAC35-110-30 Recommend a wording change in the first sentence. We would prefer to the sentence to say "Case management services are designed as applicable to assist rather than case management services shall be designed. Recommend ID/DD and MH/SU case management be separated.
12VAC35-110-40 - Recommend removal of the word "knowing" from #11 as the case manager may not always know medical information from the client as it may not be shared or disclosed.
12VAC35-110-50 - Recommend changing medical condition to medical symptoms
12VAC35-110-70 - this section specifically states that the provider shall be actively involved through face-to-face contact. Could part of these contacts be made through telehealth?
12VAC35-110-80
Section C - states the provider shall distribute the ISP to the individual and others authorized to receive it prior to implementation of the ISP. The ISP may be out in the community which would make it difficult for the case manager to distribute. Recommend removing the statement "prior to implementation of the ISP" to give case managers time to distribute the ISP instead it could state a timeframe or by the next scheduled service.
Section F - states that when a case management agency provides more than one service to an individual the agency may maintain a single document however section A & B state that a case manager shall complete a distinct, separate, initial ISP. Please clarify as the sections contradict each other.
Section I - recommend to define what readily accessible means. If a case manager must bring a printed copy of the ISP we have concerns with protecting the information during transport as it is not HIPAA compliant to make paper copies out in the community. If the case manager could have electronic access that would be more HIPAA compliant however there would be an additional cost to the CSBs.
12VAC35-110-90
Section G - same as Section I in 12VAC-35-110-80
12VAC35-110-110 If this section pertains to ID/DD services only this needs to be stated. Please clarify.
12VAC35-110-120 - for sections A. 1, 5, 6, 7, 8 please replace ensure with facilitate or coordinate. Section A is not person-centered as it is not giving the individual choice in health care. Recommend adding a statement on individual choice.
12VAC35-110-130 Please provide guidance on how to demonstrate and capture the listed competencies. Maintaining this documentation in our personnel records could cause an additional administrative burden on our administrative staff.