12VAC30-50-226A:  Certified Prescreener is a term used for CSBs/BHA clinicians who are trained and able to provide emergency services and pre-admission screenings for involutary hospitalization.  Only CSBs/BHAs provide this service and this term should only be used to describe the CSB/BHA professionals trained to provide this particular service.

12VAC30-50-226A: The new regulations require clinicians providing direct services on a full-time basis.  I am not certain what is to be gained by limiting this to full-time.  Direct services should be dictated by education and experience and not if the clinician is providing services on a full-time basis.

12VAC30-50-226A-Registration:  Registering an individual before crisis interventiion/stabilization services seems burdensome especially since the individual is experiencing a crisis and thus needs immediate attention.  Registration should be allowed within some period of time after the beginning of the crisis period (e.g. 24 hours) after an assessment can be completed.

12VAC-50-130 Activities of Daily Living:  This should be expanded to include shopping, budgeting, meal planning and medication management as these are often the activities that individuals need to live successfully in the community and prevent homelessness and hospitalization.

Finally, reimbursement should only be denied when there is substantial or significant incomplete, missing or outdated documentation.  Documentation review should be to assure that services were appropriately provided.  When minor documentation infractions have occurred and a service has obviously been provided and provided appropriately, it should be allowable for documentation to be corrected in the record.