Commenter:
Henrico Area Mental Health and Developmental Services
Overall comments regarding CPST
4.3 LMHP Oversight
Requesting reconsideration to decrease the LMHP direct involvement/availability of services due to the costs associated with obtaining and maintaining licensed staff for 24/7 service if a CSB already has an Emergency Services Department
5.) Requesting clarity regarding the LMHP required availability of 24 hours daily. Requesting Consideration for LMHP’s with Emergency Services Dept to suffice for this requirement.
6.) Requesting consideration to decrease the requirement of LMHP providing in-person services to individual every 90 days
5.1 Standardized Comprehensive Assessment of Needs and Strengths (CANS Lifetime)
Requesting a copy of the CANS Lifetime if available in order to provide comment on the assessment
Requesting clarification on if the Comprehensive Needs Assessment still required along with the CANS Lifetime for CPST?
5.3 Crisis Support
7.) Requesting clarity regarding crisis support, consideration for an Emergency Services Dept. to provide in-person crisis support
5.5 Care Coordination
1.) Requesting consideration to decrease licensing requirements to provide care coordination (BHT, paraprofessionals).
8 Exclusions and Service Limitations
2,d,iv: Requesting clarity on clinical rationale for individual’s inability to receive both CPST and Clubhouse services. Requesting consideration for both services to be provided simultaneously specifically for transitions of care since Clubhouse services may be life-long, lowest level of intervention, and potential for reimbursement to be withdrawn.
10 Additional Documentation Requirements and Utilization Review
4.) Requesting consideration for LMHP’s requirements in reviewing documentation be decreased to quarterly instead of monthly due to administrative burdens of LMHP.
