12VAC35-110-10 - thank you for defining legal guardian and comprehensive assessment. Recommend adding a definition for enhanced case management

12VAC35-110-30 Recommend a wording change in the first sentence. We would prefer to the sentence to say "Case management services are designed as applicable to assist rather than case management services shall be designed. Recommend ID/DD and MH/SU case management be separated. 

12VAC35-110-40 - Recommend removal of the word "knowing" from #11 as the case manager may not always know medical information from the client as it may not be shared or disclosed.

12VAC35-110-50 - Recommend changing medical condition to medical symptoms

12VAC35-110-70 - this section specifically states that the provider shall be actively involved through face-to-face contact. Could part of these contacts be made through telehealth?

12VAC35-110-80 

Section C - states the provider shall distribute the ISP to the individual and others authorized to receive it prior to implementation of the ISP. The ISP may be out in the community which would make it difficult for the case manager to distribute. Recommend removing the statement "prior to implementation of the ISP" to give case managers time to distribute the ISP instead it could state a timeframe or by the next scheduled service.

Section F - states that when a case management agency provides more than one service to an individual the agency may maintain a single document however section A & B state that a case manager shall complete a distinct, separate, initial ISP. Please clarify as the sections contradict each other. 

Section I - recommend to define what readily accessible means. If a case manager must bring a printed copy of the ISP we have concerns with protecting the information during transport as it is not HIPAA compliant to make paper copies out in the community. If the case manager could have electronic access that would be more HIPAA compliant however there would be an additional cost to the CSBs. 

12VAC35-110-90

Section G - same as Section I in 12VAC-35-110-80

12VAC35-110-110 If this section pertains to ID/DD services only this needs to be stated. Please clarify.

12VAC35-110-120 - for sections A. 1, 5, 6, 7, 8 please replace ensure with facilitate or coordinate. Section A is not person-centered as it is not giving the individual choice in health care. Recommend adding a statement on individual choice.

12VAC35-110-130 Please provide guidance on how to demonstrate and capture the listed competencies. Maintaining this documentation in our personnel records could cause an additional administrative burden on our administrative staff.