Definition:

“Service-specific provider assessment” means the “face-to-face interaction in which the provider obtains information from the child or adolescent, and parent or other family member or members, as appropriate, about health status. It includes documented history of the severity, intensity, and duration of health care problems and issues and shall contain all of the following elements: (i) the presenting issue/reason for referral, (ii) mental health history /hospitalizations, (iii) previous interventions by providers and timeframes and response to treatment, (iv)medical profile, (v) developmental history including history of abuse, if appropriate, (vi) educational/vocational status, (vii) current living situation and family history  and relationships, (vii) legal status, (ix) drug and alcohol profile, (x) resources and strengths, (xi) mental status exam and profile, (xii) diagnosis, (Xiii) professional assessment summary and clinical formulation (xiv) recommended care and treatment goals, and (xv) the dated signature of the LMHP.

• Definition does not take into account that  a Crisis Intervention service can be provided by a Certified Prescreener who may not be an LMHP.
• CSB’s who have a centralized intake processes would capture most, if not all, of this information at the time of an Intake. Having each service area capture all of the elements on their service specific assessments would be redundant for those individuals who are receiving multiple services simultaneously.
• LMHP level documentation for the Service Specific Assessments would not be line with the current documentation credential requirements.

Definition:

            “Certified prescreener” means an employee of either the local community services board/behavioral health service administrator or its designee who is skilled in the assessment and treatment of mental illness and who has completed a certification program approved by DBHDS.

• Definition of Prescreener
  • Removes the CSB/BHA designation as the sole entity authorized to fill the role of “Certified Prescreener”

12VAC30-50-226

            “Clinical experience” means, for the purpose of rendering (i) mental health day treatment/partial hospitalization, (ii) intensive community, (iii) Psychosocial rehabilitation, (iv) mental health support, (v) crisis stabilization, and (vi) crisis intervention services, practical experience in providing direct services on a full-time basis to individuals with medically-documented diagnoses of mental illness or intellectual/developmental disability or the provision of direct geriatric services or full-time special education services. Experience shall include supervised internships, supervised practicums, or supervised field experience. Experience shall not include unsupervised internships, unsupervised practicums, and unsupervised field experience. This required clinical experience shall be calculated as set forth in 12VAC35-105-20

• Clinical Experience
  • Full time experience requirement will be reduce the pool of potential staff and adversely affect recruitment
  • Does not allow for calculating full-time equivalent experience
  • Supervised needs further definition as it pertains to (“supervised internships, supervised practicum’s, or supervised field experience”)
  • Need clarification as to how documented proof of “supervision” is to be verified when hiring new staff
  • Need ability to grandfather current employees who meet current regs and may not meet new requirement.

12VAC30-50-226

            “Individual service plan” or “ISP” means a comprehensive and regularly updated treatment plan specific to the individual’s unique treatment needs as identified in the clinical assessment. The ISP contains his treatment or training needs, his goals and measurable objectives to meet the identified needs, services to be provided with the recommended frequency to accomplish the measurable goals and objectives, and an individualized discharge plan that describes transition to other appropriate services. The ISP shall be signed by the individual. If the individual is a minor child, the ISP shall be signed by the individual’s parent/legal guardian. Documentation shall be provided if the individual, who is a minor child is unable or unwilling to sign the ISP.

• ISP
  • Discharge Planning as part of the ISP is new.
  • Proposed regulation does not allow for documenting when an adult is unable/unwilling to sign their ISP – only allows this in the case of a child.
  • Proposed regulations by requiring the parent/legal; guardian signature on the ISP does not take into account when a child has accessed MH/SA services without parental knowledge.
  • No language about the individual being included in the development of his/her TX plan

• Register/Registration
  • Need clarification of process
  • Need clarification of time frame for notification
  • Need clarification of purpose – is this a means of DMAS/BHSA determining medical necessity (?)
  • Adds an administrative step to clinical staff for a service that is provided 24/7 when client is under extreme duress and when administrative staff are not always available.

12VAC30-50-226

• Psycho-social Rehabilitation
  • Clarification needed that QMHP can continue to conduct the assessment with an LMHP approval
  • 30 day assessment period is not included- is this an omission? Is there another time frame expected.

12VAC30-50-226

            The service-specific providre assessment, as defined at 12VAC30-50-130, shall document eh individuals behavior and describe how the individual meets criteria for this service. The provision of this service to an individual shall be registered with either the DMAS or the BHSA to avoid duplication of services and to ensure informed care coordination. This registration shall transmit to DMAS or its contractor: (i)the individual’s name and Medicaid identification number; (ii) the specific service to be provided, the relevant procedure code, begin date of the service, and the amount of the service that will be provided; and(iii) the provider’s name and NPI ,a provider contact name and number, and e-mail address.

• Crisis Intervention 
  • A Service Specific Assessment would be a hindrance to providing very short term crisis service
  • Persons in crisis are often unable to provide comprehensive information for a comprehensive service specific assessment
  • Is a service specific assessment needed when a pre-admission prescreening form is completed
  • Specification of time frame for registration would be needed.
  • Crisis Intervention is a 24/7 service. Administrative supports are not always available – so would add an administrative step to clinical staff during the visit
  • Insurance information is not always known at the time of a Crisis Intervention Service
  • Client is not always able to supply insurance information at the time of the crisis

12VAC30-50-226

Crisis Stabilization services for nonhospitalized individuals shall provide direct mental health care to individuals experiencing an acute psychiatric crisis, which may jeopardize their current community living situation. Services may be authorized for up to a 15 –day period per crisis episode following a face-to-face service-specified provider assessment by a QMHP-A or QMHP-C that is reviewed and approved by an LMHP within 72 hours of the assessment. Only one unit of service shall be reimbursed for this assessment. The provision of this service to an individual shall be registered with either DMAS or the BHSA to avoid duplication of services and to ensure informed care coordination. This registration shall transmit to DMAS or its contractor: (i) the individual’s name and Medicaid identification number; (ii) the specific service to be provided, the relevant procedure code, begin date of the service, and the amount of the service that will be provided; and (iii) the provider’s name and NPI, a provider contact name and phone number, and an e-mail address.

• Crisis Stabilization
  • Is a service specific assessment needed when a pre-admission prescreening form is completed
  • Specification of time frame for registration would be needed.
  • Crisis Stabilization is a 24/7 service. Administrative supports are not always available – so would add an administrative step to clinical staff during the visit
  • Insurance information is not always known at the time of admission
  • Client is not always able to supply insurance information
  • Amount of service can not always be determined in advance.

Definition:

“Service-specific provider assessment” means the “face-to-face interaction in which the provider obtains information from the child or adolescent, and parent or other family member or members, as appropriate, about health status. It includes documented history of the severity, intensity, and duration of health care problems and issues and shall contain all of the following elements: (i) the presenting issue/reason for referral, (ii) mental health history /hospitalizations, (iii) previous interventions by providers and timeframes and response to treatment, (iv)medical profile, (v) developmental history including history of abuse, if appropriate, (vi) educational/vocational status, (vii) current living situation and family history  and relationships, (vii) legal status, (ix) drug and alcohol profile, (x) resources and strengths, (xi) mental status exam and profile, (xii) diagnosis, (Xiii) professional assessment summary and clinical formulation (xiv) recommended care and treatment goals, and (xv) the dated signature of the LMHP.

• Definition does not take into account that  a Crisis Intervention service can be provided by a Certified Prescreener who may not be an LMHP.
• CSB’s who have a centralized intake processes would capture most, if not all, of this information at the time of an Intake. Having each service area capture all of the elements on their service specific assessments would be redundant for those individuals who are receiving multiple services simultaneously.
• LMHP level documentation for the Service Specific Assessments would not be line with the current documentation credential requirements.