Thanks for the opportunity to comment. My comments for clarificaiton or strengthening the regulations are below:

“Activities of daily living” should be defined to include “shopping, budgeting, meal planning, etc.” to be more applicable to person with mental illness.

The definition of “Certified pre-screener” needs to be brought into be brought into conformity with the Code of Virginia, assigning this repsonsibility to CSB's.

“Service specific provider assessment” leads with obtaining information about “health status” that “includes history of the severity, intensity and duration of health care problems….” While understanding health issues that may contribute or impact mental status, the main focus of the assessment is to determine MH service needs and appropriate level of service and general health information is gathered related to that. The definition should reflect this.

Any section about inadequate documentation resulted in rertaction of payment should include wording that any failure needs to be significant, not minor and incidental, or that documentation that is not in “substantial compliance with regs” will result in refusal of reimbursement. The purpose of documentation review is to assure that a covered services is delivered to a covered individual in a clinically appropriate way. It should not be about a technical “gotcha”. This is the case wherever in the proposed regulations this wording is employed.

Crisis intervention. The regulation specifying what information shall be provided to the BHSO or DMAS to register seems excessive to be in regulations and probably more than a BHSO will require. Providing name, Medicaid number and provider name and NPI and date of initiation of service should be sufficient. In this service predicting the “ amount of service that will be provided” , for instance, is not practical.

Seems to require one delivering crisis services to be a certified pre-screener because of hte use of the prposition "and" in the definition. This implies that only CSB’s or those they designate can provide this service. This is also included in the crisis stabilization section. Later in the document the prefix used is “or” which is more likely what was intended.

To qualify for ICT the standard should not be “resistance to seek out and utilize appropriate treatment options” but should be similar to that for in home services, which is akin to “When services that are far more intensive than outpatient clinic care are required and services in the home and community are more likely to be successful”. If this is adopted,  The ability to come into a clinic setting on occasion should not be a bar to getting the intensive services that are needed. The ability to keep a monthly or quarterly appointment does not connote an ability, willingness or appropriateness to come to a clinic setting multiple times a week.

Wherever the requirement to “inform” the primary care provider is included this should be qualified “with the permission of the individual or guardian.”

It should be made clear in the regs that if a service provider and the case manager are working out of the same electronic or paper clinical record that reporting requirements to the case manager are met. It is redundant to require a worker to send a report that duplicates information the case manager already has in the record they regularly access and use.