Proposed Changes |
|
12VAC30-60-181 |
Add in CSAC for 3.7- In 3.7, clients must see physician or extender for physical within 24 hours of admission. There is already ample oversight by LICENSED STAFF (EVEN MORE IN 3.7) This will increase availability as licensed staff are difficult to recruit and not available to work weekends. |
12VAC30-60-181 |
Add in CSAC for 3.7- In 3.7, clients must see physician or extender for physical within 24 hours of admission. There is already ample oversight by LICENSED STAFF (EVEN MORE IN 3.7) This will increase availability as licensed staff are difficult to recruit and not available to work weekends. |
12VAC30-60-181 |
This section is for an ISP. A Medication Assisted Treatment assessment does not belong here. It is not appropriate to have an assessment in an ISP. ISP is for client goals and must be in client language. Adding in an assessment here is inappropriate .
The assessment should be in the Assessment/ MDA. The ISP should reflect needs/goals and preferences as indicated in the assessment.
|
|
"Credentialed addiction treatment
Segment above needs to be added back in. CSACs provide essential services and should be allowed to create a substance related ISP with oversight from licensed staff. If this is left in, must address that CSACs can perform ISP’s with oversight.
If CSACs cannot complete an ISP (with sign off by licensed provider) all “Primary Counselor” staff must be licensed. This would be cost prohibitive. All BH2s would need to be converted to senior clinicians. In addition, recruitment would be impossible. Statewide, there is already a shortage of licensed staff. By adding this requirement, it will make it impossible to recruit and hire essential staff, thus reducing services available during an opioid crisis. At the very least, allow CSACs with sign off by licensed to complete ISP and MDA assessment in 3.1, 3.3, 3.5, 3.7. In these setting, there are other credentialed staff on site an available ensure the client has his/her needs met.
Add in Licensed Nurse Practitioner with experience or training in addiction medicine- Across the State, many nurse practitioners (adult or family) have extensive training and experience in addiction medicine. They should be included. |
12VAC30-130-5040. Covered services: requirements; limits; standards. |
ARTS services require a primary substance use diagnosis, and the purpose for treatment shall be related to the substance use disorder.. A CATP or a CSAC under the supervision of a CATP shall complete the multidimensional assessments. A CATP must sign and date assessments performed by a CSAC within one business day.
Evidence based approaches ( to include David Mee-Lee/chief editor of the ASAM criteria) acknowledge that individuals with co-occurring disorders can have multiple primary disorders. One is not primary over the other. Clarify wording to reflect this. The individual must have a primary substance use disorder, but that does not mean he cannot also have another primary disorder. |
12VAC30-130-5050. Covered services: clinic services - opioid treatment program services |
Leave it at 12 months versus one year. 12 month is more definitive |
12VAC30-130-5050. Covered services: clinic services - opioid treatment program services |
5. Periodic monitoring of unused medication and opened medication wrapper counts when clinically indicated.
Good |
12VAC30-130-5050. Covered services: clinic services - opioid treatment program services |
9. Women of child-bearing age shall be tested for pregnancy and shall be offered contraceptive services either onsite or through referral.
This says to test. The individual has the right to choose. This is too prescriptive. A test can be offered |
12VAC30-130-5140. Covered services: medically monitored intensive inpatient services (adult) and medically monitored high intensity inpatient services (adolescent) (ASAM Level 3.7). |
A. Medically monitored intensive inpatient services (adult) and medically monitored high intensity inpatient services (adolescent) (ASAM Level 3.7) settings for services. The facility-based
3.7 has extensive additional requirements to include expensive medical personnel. Rates for this service need to be reviewed. |
12VAC30-130-5140. Covered services: medically monitored intensive inpatient services (adult) and medically monitored high intensity inpatient services (adolescent) (ASAM Level 3.7). |
1. Daily clinical services provided by an interdisciplinary team to involve appropriate medical and nursing services, as well as individual, group, and family activity services, as appropriate to the needs and current functioning level of the individual.
It is not clinically appropriate and may often be contraindicated to begin therapy during acute withdrawal. |
Other areas that need to be changed.
Take out treatment history from ISP
It does not belong here. It is not appropriate to have an assessment in an ISP. ISP is for client goals and must be in client language. Add treatment history as part of MDA assessment. Adding in an assessment is inappropriate.
The assessment should be in the Assessment/ MDA. The ISP should reflect needs/goals and preferences as indicated in the assessment.
Discharge Planning sections for 3.3, 3.5, 3.7 are confusing and unrealistic. The time frames, especially for 3.7 is unrealistic and will result in lack on continuity of care. Programs cannot wait for the MCO to approve a discharge plan before talking to potential future providers in a short term 7 day program. This needs to be revamped.
Need to change time frame for the MDA Assessment in 3.7 programs to reflect that it is inappropriate to attempt to conduct a full psycho social history while the individual is in the acute phases of withdrawal. While the current regs allow the PDE to be delayed due to individual illness/withdrawal, the service authorization for is still expected in 24 hour but includes information that is gathered in the MDA. Specify that providers may complete service authorization form dimension 1 and 2 with 24 hours and complete the rest in 72 hours. Otherwise, the provider has to take the chance of not being paid or else must require a sick client to participate.