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CIBH thanks DBHDS for the opportunity to provide comments -
Article 1. General Provisions
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12VAC35-111-10 - Definitions
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Comprehensive Assessment
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Is the comprehensive assessment listed here the DBHDS Approved Crisis Assessment from the DMAS regulations? Clarity is needed.
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Community Based Crisis Stabilization
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It is recommended that “Community Stabilization” should be used instead of “Community Based Crisis Stabilization” to be more consistent with DMAS language and service definitions. The following definition revision is recommended:
“Community-based crisis stabilization” means services that are short-term and designed to support an individual and their natural support system following contact with an initial crisis response service or as a diversion from a higher level of care. Providers deliver community-based crisis stabilization services in an individual’s natural environment whenever feasible; services provided in a setting that is not the person’s natural environment should be clinically justifiable and with reasons for such documented in the ISP and progress notes. Providers will make referrals and linkages to other community-based services with consent by the individual, which may include linking to specialized services such as those to address needs of individuals with developmental disabilities, children, and / or individuals needing support with substances. Provision of information and / or linkages to resource assistance programs and / or benefits a person may be eligible to receive may be provided if through this linkage a person’s socioeconomic stressors are likely to be reduced and potentially reduce likelihood of future crises. The goal of community based crisis stabilization services is to stabilize the individual within their community and support the individual and/or, as appropriate, the individual’s support system during the periods 1) as a transitional step-down from a higher level of care if the next level of care service is identified but not immediately available for access or 2) as a diversion from a higher level of care.” |
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Initial Assessment
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It is unclear what is being clarified with the added language “an assessment is not a service”.
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12VAC35-111-20- Licenses
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The following licenses are recommended:
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12VAC35 – 111-30 Service Descriptions
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A – Crisis Receiving Centers
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It is indicated that a nursing assessment is required. This contradicts the regulation in the Nursing Assessment section which indicates that nursing assessments are not required for Crisis Receiving Centers on page 19.
The regulation states that CRCs shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that “the provider shall have a policy to address custody of children accompanying a parent for treatment but shall not be responsible for maintaining the children’s safety on the unit.” Additionally, there should be a requirement for addressing children being assessed at the Crisis Receiving Center to be accompanied by their parents or other legally designated substitute-decision maker. |
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B – Community Based Crisis Stabilization
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Combining multiple services under one license presents as very confusing in terms of what services are required of providers. There is a general lack of clarity and the context in which each service is provided is lost. Recommend breaking out service by service in the regulations as outlined above in the list of recommended licensed services.
It is suggested that “Emergency Services” and requirements of uniform pre-admission screening be properly defined under a unique license to reflect the codified responsibilities and training / supervision unique to this service. |
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C – Crisis Stabilization Units (RCSU)
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The regulation states that providers shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that “the provider shall have a policy to address custody of children accompanying a parent for treatment but shall not be responsible for the children’s safety on the unit.” Additionally, there should be a requirement for addressing children being assessed in a CSU to be accompanied by their parents or other legally designated substitute decision-maker.
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D
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The proposed regulation indicates that individuals cannot enter into “a REACH service” if they are actively using substances; however, this is too broad. REACH does not / should not preclude someone who is using substances from accessing REACH services.
It is agreed REACH cannot / should not support someone who is in active detox. |
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12VAC35 – 111- 40 Staffing
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B – Community Based Crisis Stabilization
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Staffing for the community based crisis continuum services is complex and even more so in this section due to the bundling of multiple services under a singular license. It is recommended that these services are broken out under separate licenses, as noted above, to ensure accurate staffing requirements are addressed.
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B2
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This requirement is believed to be a requirement of the VCC platform and is inappropriate to include in a licensing regulation.
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B3 ii
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Providers of mobile crisis response do not “dispatch” calls as this is a function of the regional hub and PRS/988. It is recommended to rephrase the regulation to read: “If a team response is recommended by the regional hub at dispatch…”
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B3 ii – 6
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It is recommended to change the language from QMHP-E to QMHP-T
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C5
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A separate license is recommended for the REACH CTH; the MCO’s accept this definition for billing purposes. We would benefit from having licensing also recognize the REACH CTHs as a setting that provides crisis stabilization services. Recommend ensuring alignment with DOJ requirements.
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12VAC35 – 111 – 50 Initial Contacts
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A
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It is recommended that “initial contact” be defined in the definitions section.
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12VAC35 – 111 – 60 Assessment
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D
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A crisis assessment is not the same thing as a comprehensive assessment due to the nature of the service and availability of records in a crisis.
It is recommended that the current DBHDS approved crisis assessment components align with the regulations as they currently do not match what is written here. The elements listed in the draft regulations are more closely aligned with a CNA than the crisis assessment. |
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H
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Record retention should not be included as it is already covered in the general regulations.
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12VAC35 – 111 – 70 Safety plans and Crisis ISP
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B
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It is recommended that a singular CEPP be required for REACH services; provisional and final CEPPs are not consistent with best practice.
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12VAC35 – 111 – 100 Progress notes or other documentation
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A
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It is recommended that these regulations be further clarified or completely omitted from draft as it is redundant to section B which includes specifics of what should be included in progress notes.
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B
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Recommend removal of this item; general regs should suffice for definition of progress note documentation
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12VAC35 – 111 – 110 Discharge Planning
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B
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It is unclear why a Crisis Receiving Center would not be required to provide discharge planning instructions and coordinate care with the rest of the service system on behalf of the individual served.
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12VAC35 – 111 - 130 Nursing assessment
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A
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This regulation does not align with DMAS regulations which require the nursing assessment at admission for any residential service and the 23-hour program. It was also noted previously that this regulation contradicts the regulation in 12VAC35-111-30. Service Descriptions (A).
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C
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The first sentence should be revised to “Prior to admission to (specify which service type)…”
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12VAC35 – 111 – 140 Health Care Policy
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B4
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It’s unreasonable to expect CSUs and CTHs providing short term services to schedule “routine ongoing and follow up” medical and dental appointments; recommend revising to reflect need for this support to address “acute” medical and dental needs only.
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C
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General regs should cover the fall risk requirements.
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