Page 5 Bullet #7: “The authorized start date of services will not be prior to the date the service authorization request is initially submitted to DBHDS for an eligible individual…… it is recommended to be submitted at least 30 days prior to the requested start of services….”
Although this is ideal situation the ongoing staffing overturn in support coordination (SC) continues to hinder providers ability to do this effectively as it is difficult to make contact with "whomever might be the current support coordinator" and depending on the location of how soon the SC is setting up team meetings being inclusive of all providers. There needs to be some flexibility and or accountability on the SC side as per recommendation of SC accountability in the review process on page 6 or approving from time provider submits to the SC.
Page 6. “Review Process: The DBHDS has 10 business days to review a request for service authorization… Upon the receipt of a response to a pend, DBHDS has 10 additional business days to process the request.”
(Agreement with vaACCSES ) Please add guidance for similar timeframe expectations for the SC/CM to submit requests and responses to DBHDS. Complaints about SC/CM refusals and delays in submitting requests and responses to pends to DBHDS are increasing while DMAS regulations and guidance are silent. Please consider guidelines for the SC/CM or CSB responsibilities for providing appeal information and rights if they cannot submit requests or pend responses within 5 business days of receiving the required documents and/or response from the provider.
Page 17 in the 4th paragraph:“Community Guide activities conducted not in the presence of the individual, such as researching and contacting potential sites, supports services and resources, shall not comprise more than twenty-five percent of authorized plan for support hours.”
Comment: (Agreement with Hope House Comment) -Allowing only 25% of the research and contacts to be outside of the presence of the individual is not reasonable in today’s housing or community climate as we are slowly returning to non-pandemic realm and the documentation processes that need to occur.
Recommendation: This piece should be increased to 50% of the allowable hours and should allow phone/telehealth meeting options to increase efficiencies.
Also would recommend a better delineation of Community Guide service definition as some interpret it as all about housing vs the option of community connections and that a provider might only be doing one part vs. another.