Major concern regarding the proposed rate will not support this service or the staffing model long-term.... the proposed rate is below the current rate, and many programs already operate PSR in the red from a budgetary perspective.
The annual assessment, do we have to use the CANS lifetime, that is not clear or current CNA for PSR?
3.2 Service Planning= what is meant by ISP must be overseen by LMHP? By signature? By signing QR? unclear
3.3 RSB... major concerns regarding the population RBHA PSR serves, many of which are geriatric and not interested or appropriate for work or school; concerned that such a large focus is placed on employment and education for a population that is disinterested in those areas more interested in maintenance and symptom management.
3.4 Crisis Support= requiring PSR staff to respond to crisis's and disallowing the use of the crisis continuum seems to punish the recipient and is a huge training concern for current PSR staff; this also seems to negatively impact traditional and mobile crisis and stabilization.
5.1 Medical Necessity= requiring SMI still? not clearly stated.
6.10 Exclusions= Disallowing ACT, ASAM, and CSC is VERY problematic, especially ACT. This is punishing clients who gain much support from PSR and remain stable in the community due to increased monitoring and support PSRs provide. A large number of our current membership is engaged in ACT.
8.4 Additional Doc.= LMHP to review documentation of non-licensed staff every 30 days; this is an administrative burden on supervisors/managers; how would this be done? Reviewing and signing all progress notes is unrealistic and not good use of supervisory time. Would suggest that only QMHP-T requires double signature of notes.
The description of the activities listed in the “Required Service Components” seem like they overlap with Case Management, ES, and Skill Building.
Any observation without an intervention is not a billable activity” Does this mean that we cannot bill for someone who comes to the program and just sits, and doesn’t interact? This would eliminate the ability to bill for several members who spend the day sleeping or just need time to themselves.
The included chart on page 7 is confusing. Is this just an example? Right now, we can bill max 360 units per six-month period, but the example shows only 240 units a year.
The very first clubhouse international standard is that membership is without time limits, and yet it appears that the MCO’s want to limit the time a person is enrolled.
There is a standard (standard 25) in Clubhouse International regs that supports in house education opportunities, and yet that is on the list of non- billable activities.
