Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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9/29/21  4:46 pm
Commenter: Adrien Monti, BRBH

Appendix E Assertive Community Treatment ACT
 

Appendix E:

  • Recommend changing “youth’s” to “adult’s” under “Required Activities” because ACT generally serves adults - bottom of page 6

“ISPs must be reviewed as necessary at a minimum of every 30 calendar days or more frequently depending on the youth’s needs. Refer to Chapter IV for additional guidance and documentation requirements for the 30 calendar day review as well as additional quarterly review requirements.”

  • Recommend reconsideration of completion of psychiatric evaluation on date of admission on page 6 under “Required Activities”. Would recommend that the soonest available appointment be made within the state required timeframe upon discharge. Availability of psychiatric provider may be limited and service provision such as medication deliveries and follow-up by other ACT staff may be needed prior to the psychiatric evaluation being completed. For example, if a client is discharged from the hospital and is provided with 7 days of medications, these may need to be delivered daily prior to the psychiatric appointment.

“Medication prescription monitoring must be provided by a psychiatrist or psychiatric nurse practitioner who completes a psychiatric evaluation an initial assessment on the day of admission and has contact with individuals on a quarterly basis.”

  • Recommend rephrasing of the inability to provide concurrent authorized services on page 7 under “Service Limitations” as ACT may not offer all services a client may need such as Applied Behavior Analysis, Functional Family Therapy, SUD Intensive Outpatient Group Counseling or psychosocial rehabilitation. Would suggest rephrasing to “ACT may not be authorized to provide services that overlap with eligible additional services based of authorization and client need…”

“ACT may not be authorized concurrently with Individual, Group or Family Therapy, Addiction and Recovery Treatment Services (ARTS) and Mental Health (MH) Intensive Outpatient, Outpatient Medication Management, Therapeutic Day Treatment, Intensive In Home Services, Crisis Community Stabilization, Mental Health Skill Building, Applied Behavior Analysis, Multisystemic Therapy, Functional Family Therapy, Psychiatric Residential Treatment Facility (PRTF), Therapeutic Group Home (TGH), ARTS Level 3.33.1-3.7 or Manual Title Mental Health Services (formerly CMHRS) Chapter App. ED Page 8 Chapter Subject Intensive Community Based Support Page Revision Date TBD Peer Recovery Support Services, as the activities of these services are included in the per diem.”

  • Recommend the following change on page 13 under Medical Necessity Criteria:

Allow a nurse practitioner to write a letter justifying an exception for diagnoses that fall outside the SMI definition depending on the level of associated long-term disability; regulations currently restrict this to a physician.  Now that ACT teams can employ nurse practitioners, they should have the authority to write a letter such as this.

  1. “Individuals with psychiatric illnesses that fall outside the serious mental illness definition may be eligible depending on the level of associated long-term disability; in these cases, a Physician letter justifying this exception should accompany the service authorization request.”

 

  • Recommend the following change on page 18 under Service Authorization:

Services required for continuity of care should be allowable prior to completion of psychiatric evaluation or the comprehensive needs assessment if needed such as medication delivery upon discharge from hospitalization. An established date of psychiatric evaluation and/or comprehensive needs assessment should be documented in accordance with completion requirements and authorization guidelines.

“If the psychiatric evaluation required for admission is unable to be conducted on the same day as the comprehensive needs assessment, the provider shall submit the service authorization request within one business day of completing the psychiatric evaluation. If submitted in this timeframe, the MCO or FFS contractor shall honor the date of the comprehensive needs assessment as the start date of services, however, ACT services other than the comprehensive needs assessment or psychiatric evaluation may not be provided until both the comprehensive needs assessment and psychiatric evaluation are completed.”

CommentID: 100796