Agencies | Governor
Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Previous Comment     Next Comment     Back to List of Comments
10/26/21  5:05 pm
Commenter: Sean Runyon

Medicaid Reg Feedback/Questions

Hello, Please see several questions below:


Pg 31 - 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.


  • What is considered the “start of services?”  During the referral process? How do you all interpret this statement?


Pg 32 -  A psychiatric evaluation by a psychiatrist, nurse practitioner or physician assistant must be available at the time of admission into the service.


The question here is: must be available at the time of admission into the service.

  • This looks like a psychiatric evaluation MUST be completed at the time of admission.  It says, “available.”   Are we talking prior to admission or at admission? 


Pg 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.


  • My agency uses a Safety & Wellness Plan that incorporates the elements of the CEPP.  Will that document suffice?  


Pg 33 - On the day of admission, at a minimum, RCSU providers must provide assessment, psychiatric evaluation and a nursing assessment.


  • Which assessments and by whom?  Can a psych assessment w/n 24 hrs suffice?  What about an med review w/ telephone order read back (TORB)?

Pg 34 - Services may not be provided in other locations outside of the licensed site. Services shall not be provided for the sole reason of providing temporary housing to an individual; if the individual meets other admission criteria and housing is an additional assessed need, this should be noted on the service authorization request to support continued coordination of resources for the individual.


  • Mostly an FYI on this b/c we sometimes get push back on this a lot from MCO's to deny service.


Pg 36 - Individuals must meet all of the following criteria: 1. Documentation indicates evidence that the individual meets criteria for a primary diagnosis consistent with the most recent version of the Diagnostic and Statistical Manual 2. One of the following must be present:

a. The individual is currently under a Temporary Detention Order; b. Abrupt and substantial changes in behavior noted by severe impairment or acute decompensation in functioning related to a behavioral health problem; c. Actual or potential danger to self or others as evidenced by: a. Suicidal thoughts or behaviors and/or recent self-injurious behavior with suicidal intent; or b. Homicidal ideation; or c. Command hallucinations or delusions d. Significant loss of impulse control that threatens the safety of the individual and/or others or their ability to take care of themselves; e. Significant inability to maintain basic care for oneself and to keep oneself safe in the community in an age appropriate manner that is not associated with Dementia; f. Substance intoxication with suicidal/homicidal ideation or inability to care for self.


  • My interpretation of this is that where admission criteria previously required 2 (of the 4) criteria to be present, there will only be 1 of the above, plus supporting documentation.  That would require the prescreen to be updated; my CSU Referral Form to be updated (approved by DBHDS); and several CSU forms. This criteria is pretty different. Thoughts?


Pg 38 – Just a crucial observation.  I see it will be complicated to justify Continued Stays.  The pt has to meet ALL 8 criteria, but only 1 for admission.  That said, I would wager that none of our detox pts will meet ALL of these 8 criteria for Continued Stay and will likely get denied after the initial 5 day PA.


Pg 39 - RCSU services are initially authorized through a registration process for 5 calendar days/5 units. Submission of registrations must be within 1 business day of admission.


  • I’m still looking for clarification on what constitutes a “business day” since every day is a business day for CSU.  Do we still have until 11:59pm the following business day?


Pg 39 - If additional activities beyond 5 calendar days/5 units are clinically required, the provider shall submit an authorization request to the FFS contractor or MCO through a continued stay service authorization request accompanied by a CEPP submitted no earlier than 24 hours before the requested start date of the continued stay.


  • Same question as earlier…Will the my agency Safety & Wellness Plan suffice for the CEPP?
  • The second question is, b/c of this timeframe, anyone who is admitted on Tuesday or Wednesday will now need a Continued Stay over the weekend.  We do not presently discharge over the weekend due to challenges with care coordination.  We will either now be losing money; just housing them; or have to change our model to discharge over the weekend.  This is a major programmatic barrier.


Pg. 39 - The day of discharge is not billable.


  • Is the day of admission definitely billable?

Thank you!

CommentID: 116568