3. Required Service Components

3.2 Service Planning

4. The ISP may be developed through a team approach and must be authorized and overseen by either the Clinical Director or Program Director.

Please provide more clarity on this statement. Does authorized mean review and signed off on by clinical director or program director?  I agree with a comment made by another reviewer that stated: “Allowing a LMHP, LMHP-R, LMHP-RP, LMHP-S to authorize and oversee the ISP is clinically appropriate.” 

5.1 Clubhouse Admission Criteria

 Completion of an in-person Comprehensive Needs Assessment by a LMHP, LMHP-R, LMHP-S, or LMHP-RP within 30 days prior to admission.

              This needs clarification as I agree with others who have said it could result in delayed billing and services to those referred to our program. The current initial psychosocial assessments our program completes is very thorough and provides appropriate clinical information needed to determine eligibility.

2. Diagnostic Criteria: must meet a: The member must have a documented DSM diagnosis that is consistent with a serious and persistent mental illness, including but not limited to, the following DSM categories: Schizophrenia Spectrum and Other Psychotic Disorders; and Bipolar and Related Disorders. members with diagnoses that fall outside of these categories may be eligible depending on the level of associated long-term disability; in these cases, a physician letter (documentation from a physician) justifying this exception should accompany the service authorization request. Members may also have a co-occurring diagnosis of a substance use disorder or developmental disability

Requiring a physician letter for members with diagnosis that fall outside of SMI categories could delay the admission process. It’s an extra step that seems unnecessary when the initial assessment is required to be completed by an LMHP who can justify the need for services in the assessment itself.

6. Exclusions and Service Limitations

10. Members receiving Clubhouse may not be authorized to receive the following services: a. Individuals receiving Clubhouse may not receive the following services:

ii. Addiction and recovery and Treatment Services (ARTS) Levels: ASAM 2.1-.3.3

iii. Assertive Community Treatment,

iv. Coordinated Specialty Care,

Excluding individuals who receive the above services is doing a severe disservice to the individual as many current PSR clients receive the above services and attend PSR. These have higher needs and significantly benefits from daily structured activities to enhance their recovery. Rehab and treatment are not one in the same and should not be treated as such. Excluding individuals from an opportunity to participate in a program that currently helps them learn to be more independent and function independently in their community is wrong and slows down their recovery.

8. Additional Documentation Requirements and Utilization Review

3.e. The only staff who may complete a progress note is the staff who delivered the service. It is not permitted for a staff to deliver the service and another staff to document and/or sign the progress notes.

We agree with the following statement made by another commentor: “As most programs provide multiple activities in a milieu/ team approach within the month the progress note covers, this requirement is confusing. Currently, we have each staff write the monthly progress note for their assigned clients with input from the team.  Please delete this requirement or clarify further.”

4. An LMHP must review documentation of non-licensed staff at least every 30 calendar days as evidenced by a progress note in the member’s chart written by the LMHP or a co-signature on the non-licensed staff’s progress notes. Non-licensed staff include LMHP-Rs, LMHP-RPs, LMHP-Ss, QMHPs, QMHP-Ts RPRSS and BHTs

This is an unrealistic expectation as the number of LMHP staff is limited on the team. Therefore the expectation to review and/or sign every documented note in every client chart is extremely burdensome. Consider putting in internal chart audit expectations where an LMPH can attest to reviewing a specific number of client charts each month and documenting the audit was completed.  

9. Clubhouse Billing Requirements and Information

1. One unit of service is one day.

2. To bill the per diem unit, members must receive a minimum of two required activities on the day of service. At least one of the required activities shall be in-person.

Please provide clarity on billing expectations if the billing will change to per diem rate. Stating a member must participate in 2 required activities at least one of those activities shall be in-person leads us to believe billing can occur for non in-person activities which contradicts some of the billing services listed throughout the document.