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Board of Medical Assistance Services
 
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7/26/18  4:36 pm
Commenter: Yvonne Russell, Henrico Area Mental Health & Developmental Services

HAMHDS comments on the proposed Psychiatric Manual Chapter II, IV and VI
 

Psychiatric Services Manual

Psych Svcs

II

4

Recovery is built on access to evidence-based clinical treatment and recovery support services for all populations.  Since the National Registry of Evidence Based Practices is no longer active, how is evidence based clinical treatment currently defined?

 

 

 

16

Providers must report any knowledge of adverse outcomes for an individual currently receiving services or who have been discharged from services within 180 days of the incident.  How would we operationalize reporting of incidents involving clients who have been discharged.  For example if we discharged a client from services and 4 months later ESP is contacted to do a prescreening on the same individual following a suicide attempt, would we be required to notify DMAS and, if yes, through what format?  

Psych Svcs

IV

31

Outpatient psychiatric services

All psychiatric services, including medication management shall be medically prescribed treatment, documented in an active written treatment plan.  Our outpatient services are therapy, seems to indicate that they must be prescribed by the physician.

 

 

32

…each mental health clinic must ensure that the federal requirement for the physician direction of the clinic is fully met.  This is language from the clinic option manual.

 

 

33

The requirement for physician supervision of all patient care in the mental health clinic is a condition of Medicaid reimbursement for mental health clinic services. The physician must have a face-to-face visit with the individual, prescribe the type of care provided, and if services are not limited by the prescription, periodically review the need for continued care. 

This is currently not our practice and would be extremely difficult to implement.

Seems to indicate this is including therapy since it is in the outpatient services section.

“If a plan of care is implemented, there must be no more than 3 sessions or no more than thirty days, whichever is least, before the face to face interview with the physician.”

 

 

36

The initial POC must be completed prior to the start of services. (p. 36)   How is this possible—isn’t the POC a collaborative process with the client?  Is development of the POC billable?

 

 

36

The POC must indicate “treatment modalities used and documentation specific to the appropriateness of the modalities”. This is language from the clinic option manual and has never been a requirement for outpatient services working previously from the psychiatric manual.

 

 

37

The individual must participate and be compliant with treatment (e.g., some individuals with intellectual disabilities [ID] or children may not have the ability to understand the treatment) How is compliance with treatment defined? 

 

 

40

Staff must be proficient in the operation and use of telemedicine equipment. How is proficiency defined?

Psych Svcs

VI

10

  All services require a Service Specific Provider Intake (SSPI)comprehensive needs assessment which is required at the onset of services. The SSPI comprehensive needs assessment must be completed face to face by an LMHP, LMHP-S, LMHP-R, or LMHP-RP. This contradicts the exclusion in Chapter 4 that Case Management Comprehensive Needs Assessment can be completed by QMHP. Please add clarification.

 

 

CommentID: 65880