Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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12/3/25  2:14 pm
Commenter: Hank - Norfolk CSB

Clubhouse comments
 

Under 3.1.2 there is a requirement that the CNA be completed. These individuals presumably would also have to go through Same Day Access to access services, or would this assessment be a separate route of entry for Clubhouse members outside of SDA? If they do need to go through SDA, a second CNA seems unnecessary

Under 3.2.4, it states the Clinical Director or Program Director must oversee the ISP. Are these synonymous titles? Clinical director is not delineated in 4.1

Under 3.2.6, My assumption is "all required service components" are those listed as 3.2.1, 3.2.2, 3.2.3, 3.2.4, 3.2.5 and 3.5. Of those, 3.2.3 is the one likely to be provided the most often for documentation towards the ISP. Should these more infrequent components be listed "as needed" in relation to frequency on the ISP? The concern is that all required service components may not align with all individuals needs at time of initial assessment

Under 3.3.7, how many evenings, weekends per month and holidays of the year must there be activities?

Under 3.4.2, Is the crisis mitgation plan exist as part of the ISP as referenced as a service component in 3.2.6?

Under 3.4.3-5, are these crisis supports meant to be offered during clubhouse activities only? If they are, is the inclusion of 3.5 necessary as all will be on site? The only activity where face-to-face, i.e telemedicine, is mentioned the assessment and explicitly states this must be in person at home or location of choice

Under 3.5, what lower levels of care would be stepped down to with services sunset as part of BH redesign?

Under 4.2.1, licensing is required for reimbursement, although this will not be possible for some time. Can the exception given for those seeking licensing be added in as a clause from time of intiiation until year XXXX deadline

Under 4.2.2, what is the timeline for provider specialty determination?

Under 4.3, accreditation may take longer than 4 years. Will a mechanism be added to file for extension or is it a hard deadline?

Under 4.4.1, would the operating hours apply to the weekend, holiday, and evening requirements?

Under 5.5.1.a, would this CNA be through SDA or the 2nd one completed by Clubhouse staff? Or would either suffice if a client has not had a CNA through SDA within the past 30 days as they have been open to another service?

Under 5.1.2-3, would the SMI Criteria form and/or the DLA 20/WHODAS suffice for this requirement?

Under 5.3, Per Clubhouse accreditation standards members are members for life. How would we reconcile this directive with those standard requirements?

Under 7.1 and 7.2, Is the initial CNA listed meant to be that completed by Clubhouse, SDA, or both? Additionally, can you explain the rationale for inclusion of the initial ISP?

Under 8.4, can you please explain the rationale of the review by an LMHP on all documentation?

Under 9.2, is this two different categories(3.1, 3.2, 3.3, 3.4, 3.5) or can two different RSB services under 3.3 suffice?

CommentID: 238368