Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
Action Allowing a grace period for documentation of ISPs
Stage Fast-Track
Comment Period Ended on 3/6/2019
spacer
Previous Comment     Next Comment     Back to List of Comments
2/25/19  12:24 pm
Commenter: Michele M. Elliott, Hanover County Community Services Board

12VAC35-105-675. Reassessments and ISP reviews
 

There is concern about the change in due dates for reviews.  Currently direct service providers are required to send their quarterly report to the Case Manager within a 10 day grace period and the Case Manager then has 30 days from the end of the quarter to review the services provided.  There are several providers who do not send their quarterly reports within the 10 days and some that do not send the report by the Case Manager’s 30 day grace period.   For example, in the month of December 2018, Hanover County DD Services had a total of 57 quarterlies to complete by December 31, 2018;  21 were not received within the 10 day grace period. The Hanover County Case Manager’s standard response is  to follow up with the provider with at least two phone calls  and  then a standard letter is sent to the provider which is copied to the DBHDS Community Resource Consultant.  By December 31, 2018, 15 quarterlies were not received by the case manager’s 30 day grace period. In January, 45 quarterlies were due, 18 were not received by the 10 day grace period and 7 were not received by the end of the month after the Case Manager’s attempts to receive the review.    

If the Case Manager is going to be required to complete a quarterly review by the 15th day of the month, then provider information will likely not be included.  To meet the expectations of the DOJ Settlement, Case Managers must have the time to review the provider information.   We would like to suggest that the providers of direct services be allowed a 15 day grace period to complete their quarterly and that Case Management services be required to complete the quarterly review no later than 30 calendar days from the date of the end of the review period.  We would also like to see language added to describe how providers are to be held responsible by Licensure if a quarterly is not received within the grace period, as well as a description of expectations of the Case Manager in obtaining the quarterly.  Language should also be added to reflect the responsibility of DBHDS staff in providing oversight to those providers who consistently miss sending requested quarterly information. 

Thank you for your consideration of these comments.  If you need any further information, please feel free to contact me. 

CommentID: 69265