12VAC30-50-226A – Community Mental Health Services: The term certified pre-screener is a term that, in Virginia, is considered to be exclusive to the CSB/BHA clinicians who provide emergency services and pre-admission screening for involuntary detention. This proposed change would be in conflict with the current Code of Virginia and DBHDS Licensing Regulations.

12VAC30-50-226A - Requiring “full time experience” would reduce the pool of potential staff and adversely affect recruitment (i.e.: caregivers, part-time workers). There is also need for guidance on the calculation of “clinical experience”. There needs to be a clear definition of the meaning of “supervised”. Also, what is the expectation of how internships, outside of the hiring entity, would be handled or documented?

12VAC30-50- 226A: Too many disciplines are being excluded. Nursing is not included as a human services field and should be noted in the list.  How will staff hired under the current list of disciplines be grandfathered?

12VA30-50-226 – ISP: Loss of person centered language is very concerning.  This should be added back into this section. In addition, providers with EHR’s will need time to reconfigure to meet any new requirements.

12VAC30-50-226A – QMHP-A and C: How will grandfathering and variances be handled related to staff already hired – this is a critical issue. This change will impact the pool of potential staff and adversely affect recruitment. 

12VAC30-50-226A – LMHP – it is our understanding that the psychiatric clinical nurse specialist will no longer be an obtainable specialty after 2013, as Masters’ level nurses are now being educated and will be credentialed (board certified) to provide services to children, and adults as nurse practitioners. The language will still need to reflect both psychiatric clinical nurse specialists and psychiatric nurse practitioners as those who are currently double board certified will be grandfathered.

12VAC30-50-226A-Registration: When CSB/BHA clinicians are addressing emergency situations, triage and stabilization, this should be allowed and a priority followed by a Registration.  This will add another administrative step, which we believe is already accomplished by filing a claim. Based on this requirement, will Crisis Stabilization and Detox programs still be able to do 24/7?

12VAC30-50-226B: Day Tx - Will existing variances be honored?

12VAC30-5-226B:  There is a need to clarify that a QMHP-A can continue to conduct the face to face assessment with the LMHP approval.

12VAC30-5-226B: Psychosocial Rehab. – Will existing variances be honored?  What about for LPNs?

12VAC30-5-226B1-Service-specific provider assessment:  Please clarify, what is this?  Is this the same as a comprehensive assessment? 

12VAC30-50-226B - Crisis Intervention: Amount of service that will be needed and provided can hardly be determined in advance.  Individuals in crisis can rarely provide comprehensive information so triage and stabilization is necessary before registration of any kind.   What will happen if the computers are temporarily down or for some other reason staff cannot reach DMAS? Individuals, in this case, may not always be able to provide Medicaid information for registration. As proposed, this registration would be completed only by a certified pre-screener, requiring that the evaluator would need to be an LMHP, QMHP and a pre-screener.  This would disallow many of the CSB current staff to perform this service, since not all of our pre-screeners are licensed.

12VAC30-50-226B “Intensive Community Treatment”: Licensure through DBHDS for this service is based upon the national PACT model. Removing case management as a required component conflicts with the national PACT fidelity standards.  Individual at this level of care require case management to assist with diversion from hospitalization and to assist with basic needs.

12VAC30-50-226B – Crisis Stabilization services regulations indicate that services are based on the assessment of a QMHP that are then later reviewed and approved by a LMHP within 72 hours. The LMHP is only reviewing and approving the service rather than performing the face to face assessment. Considering the acuteness and brevity of the service, at 3 days the consumer is often discharged.  In order to provide the level of service that is needed for crisis stabilization services the LMHP needs to be more actively involved in the assessment and treatment planning in the early stages of treatment, which would then provide the information necessary for service authorization and also provide for more delineation of the service from crisis intervention and mental health supports.

12VAC30-50-226B5: Crisis Stabilization: Must staff now be both LMHP, QMHP-A or QMHP-C and a certified pre-screener?

12VAC30-60-143-PCP Notification:  With language that assures recipient’s consent to the notification, fully support coordination with PCP.

12VAC30-50-130-5: Community Mental Health Services: The term certified pre-screener is a term that, in Virginia, is considered to be exclusive to the CSB/BHA clinicians who provide emergency services and pre-admission screening for involuntary detention. This proposed change would be in conflict with the current Code of Virginia and DBHDS Licensing Regulations and removes the CSB/BHA designation as the sole entity to fill the role of certified prescreener.

12VAC30-50-130-5: Requiring “full time experience” would reduce the pool of potential staff and adversely affect recruitment (i.e.: caregivers, part-time workers). There is also need for guidance on the calculation of “clinical experience”. There needs to be a clear definition of the meaning of “supervised”. Also, what is the expectation of how internships, outside of the hiring entity, would be handled or documented?

12VAC30-50- 130-5: Too many disciplines are being excluded. Nursing is not included as a human services field and should be noted in the list.  How will staff hired under the current list of disciplines be grandfathered?

12VA30-50-130-5: ISP: Providers with EHR’s will need time to reconfigure system capabilities to meet any new requirements. Discharge plans are currently included in a variety of ways including in ongoing assessments.

12VAC30-50-130-5: QMHP-C: How will grandfathering and variances be handled related to staff already hired – this is a critical issue. This change will impact the pool of potential staff and adversely affect recruitment. 

12VAC30-50-130-5: LMHP – Substance Abuse practitioners are certified not licensed. 

12VAC30-50-130-5: Intensive In-Home:  IIH is one of the most intensive community cased mental health services provided to children and adolescents with serious emotional disorders (SED).  SEDs are chronic conditions that persist over time and it is essential that children and adolescents with DED receive targeted case management services independent of IIH to ensure that clinical needs of these children and adolescents are being met effectively, coordinated and addressed.

12VAC30-60-61A-Definition of “at risk”:  This more stringent definition in the proposed changes may easily result in fewer children and adolescents with SED qualifying for Intensive In-Home.  If a service such as the Strategic Family Services and Supports Services Model were available, this definition may not have the potential to deny services to those who need them.  That service is not in place, however, and outpatient, clinic-based services may not meet the need.  Again, flexibility and an exception process are needed. This model is designed by the VACSB, endorsed by Voices for VA’s Children.

12VAC30-30-60-143: Support PCP Notification with appropriate client Authorizations in place.

12VA30-130-3010:  Removes the CSB/BHA designation as the sole entity authorized to perform independent clinical assessments.

12VA30-130-3030A:  IIH -Removes the CSB/BHA designation as the sole entity authorized to perform

12VA30-130-3030B:  TDT -Removes the CSB/BHA designation as the sole entity authorized to perform independent clinical assessments.