Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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11/5/21  10:28 am
Commenter: Fairfax-Falls Church Community Services Board

Draft Mental Health Services Manual- Appendix G
 

 

Fairfax- Falls Church Community Services Board agrees and supports all the comments/feedback to date below:

  1. App. G, Comprehensive Crisis Services

 

Pages: 7-8  The following required activities apply to Mobile Crisis Response: · A referral from the Crisis Hotline is required. · At the start of services, a LMHP, LMHP-R, LMHP-RP or LMHP-S must conduct an assessment to determine the individual’s appropriateness for the service. This assessment must be done in-person or through a telemedicine assisted assessment. At a minimum, the assessment must include the following elements: risk of harm; functional status; medical, addictive and psychiatric co-morbidity; recovery environment; treatment and recovery history; and, engagement. · If there is an existing Crisis Education and Prevention Plan (CEPP), the provider should, at a minimum, review the CEPP and update as necessary. · Services must be provided in-person with the exception of the telemedicine assisted assessment and care coordination activities. · Providers must follow all requirements for care coordination (See Care Coordination Requirements of Mental Health Providers section of Chapter IV).

 

  • Comments/feedback: Please provide additional information on procedures and implementation standards around the Mobile Crisis Response Services. In addition, guidance is being requested on how to operate the Mobile Crisis Response Services.

 

  1. App. G, Comprehensive Crisis Services

 

Page: 8  If there is an existing Crisis Education and Prevention Plan (CEPP), the provider should, at a minimum, review the CEPP and update as necessary. · Services must be provided in-person with the exception of the telemedicine assisted assessment and care coordination activities. · Providers must follow all requirements for care coordination (See Care Coordination Requirements of Mental Health Providers section of Chapter IV).

 

Page: 16  A Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements is required for Community Stabilization and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S. · If an individual is transitioning between crisis services, the provider may review and update an existing CEPP in accordance with DBHDS guidelines. · CEPPs must be reviewed and updated as an individual moves between crisis services (Mobile Crisis Response, Community Stabilization, Residential Crisis Stabilization Unit, 23-Hour Crisis Stabilization) according to DBHDS requirements.

 

Pages: 24-25  The Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements is required for this service and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S. · CEPPs must be reviewed and updated as an individual moves between crisis services (Mobile Crisis Response, Community Stabilization, 23-Hour Crisis Stabilization, Residential Crisis Stabilization Unit) in accordance with DBHDS guidelines.

 

Page: 32 The Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements is required for this service and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S. · CEPPs must be reviewed and updated as an individual moves between crisis services (Mobile Crisis Response, Community Stabilization, Residential Crisis Stabilization unit, 23-Hour Crisis Stabilization) according to DBHDS requirements.

 

  • Comments/feedback: Consider the use of the current documents being utilized within the agency to assist with meeting this requirement. If the documentation process changes, this will create a burden on agency staff to integrate new documentation requirements within a short time frame. Please allow a grace period from the go live date to provide agency staff time to learn and implement any new documentation requirements.
  1. App. G, Comprehensive Crisis Services

Pages: 7-8 The following required activities apply to Mobile Crisis Response: · A referral from the Crisis Hotline is required. · At the start of services, a LMHP, LMHP-R, LMHP-RP or LMHP-S must conduct an assessment to determine the individual’s appropriateness for the service. This assessment must be done in-person or through a telemedicine assisted assessment. At a minimum, the assessment must include the following elements: risk of harm; functional status; medical, addictive and psychiatric comorbidity; recovery environment; treatment and recovery history; and, engagement.

Pages: 15-16 The following required activities apply to Community Stabilization: · A referral from the Crisis Hotline is required. · At the start of services, a LMHP, LMHP-R, LMHP-RP, LMHP-S must conduct an assessment to determine the individual’s appropriateness for the service. This assessment must be done in-person or through a telemedicine assisted assessment. The assessment requirement can be met by one of the following: 1. Providers may choose to complete a Comprehensive Needs Assessment (see Chapter IV for requirements). 2. If a prescreening assessment has been completed within 72 hours prior to admission, the LMHP, LMHP-R, LMHP-RP or LMHP-S may review and create an update or addendum to the prescreening assessment. 3. A DBHDS approved assessment for crisis services can be used to meet this requirement if conducted by a LMHP, LMHP-R, LMHP-RP, or LMHP-S.

Page: 24 The following required activities apply to Community Stabilization: · A referral from the Crisis Hotline is required. · At the start of services, a LMHP, LMHP-R, LMHP-RP, LMHP-S must conduct an assessment to determine the individual’s appropriateness for the service. This assessment must be done in-person or through a telemedicine assisted assessment. The assessment requirement can be met by one of the following: 1. Providers may choose to complete a Comprehensive Needs Assessment (see Chapter IV for requirements). 2. If a prescreening assessment has been completed within 72 hours prior to admission, the LMHP, LMHP-R, LMHP-RP or LMHP-S may review and create an update or addendum to the prescreening assessment. 3. A DBHDS approved assessment for crisis services can be used to meet this requirement if conducted by a LMHP, LMHP-R, LMHP-RP, or LMHP-S.

 

Pages: 31-32 The following required activities apply to RCSUs: · At the start of services, a LMHP, LMHP-R, LMHP-RP or LMHP-S must conduct an assessment to determine the individual’s appropriateness for the service. The assessment requirement can be met by one of the following: 1. Providers may choose to complete a Comprehensive Needs Assessment (see Chapter IV for requirements). 2. If a prescreening assessment has been completed within 72 hours prior to admission, the LMHP, LMHP-R, LMHP-RP or LMHP-S may review and create an update or addendum to the prescreening assessment. 3. A DBHDS approved assessment for residential crisis stabilization services can be used to meet this requirement if conducted by a LMHP, LMHP-R, LMHP-RP, or LMHP-S.

  • Comments/feedback: Allow the use of existing pre-screening and or the PDE assessment within the agency. If the assessment documentation changes, this will create a burden on agency staff to integrate the new documentation requirements within a short time frame. Please allow a grace period from the go live date to provide agency staff time to learn and implement any new documentation requirements.
  1. App. G, Comprehensive Crisis Services

 

Page: 11 Consent for a voluntary evaluation and mobile crisis response intervention is refused.

 

Page: 20 Individuals who meet any of the following criteria are not eligible to receive Community Stabilization services: 1. The individual’s psychiatric condition is of such severity that it can only be safely treated in a 23-hour crisis stabilization, residential or inpatient setting; 2. The individual’s acute medical condition is such that it requires treatment in an acute medical setting; 3. The individual/parent/guardian does not voluntarily consent to treatment.

Page: 29  Individual or parent/guardian withdrawal of consent for treatment with the exception of cases that are under an ECO or TDO;

 

Page: 37 Any one of the following criteria is sufficient for exclusion from this level of care: 1. The individual’s psychiatric condition is of such severity that it can only be safely treated in an inpatient setting due to violent aggression or other anticipated need for physical restraint, seclusion or other involuntary control; or 2. The individual’s medical condition is such that it can only be safely treated in a medical hospital as deemed by a physician; or 3. The individual does not voluntarily consent to admission with the following exceptions: o The individual has agreed at an involuntary commitment hearing to a voluntary placement within an RCSU and are ordered to remain for 72 hours and must provide 48 hours’ notice of intent to leave; or  The individual is committed through an involuntary commitment hearing to an involuntary placement within the RCSU

 

  • Comments/feedback: Allow verbal consent for all services. In addition, allow for agency staff to make clinical decisions when an individual is experiencing severe symptoms and crisis that impacts their impairment to authorize consent and or understand the consent for treatment authorization that is needed to help sustain their mental and physical health well-being.
CommentID: 116688