12VAC30-50-130

• The ADL definition should say “... personal care activities including ...” and should include money management , shopping, meal planning, etc.
• QMHP-E should be included as a definition; there is a definition in DBHDS at 12VAC35-105-20
• IIH - the term “care coordination” has replaced “case management” as a component; care coordination refers to collaboration and sharing of information among health care providers who are involved with the individual; add “If Case Management services pursuant to 12VAC30-50-420 or 430 are not being received, it is critical that the IIH provider link the individual and/or his parent or guardian with services and supports necessary to maintain or improve the stability of the home and family.”

12VAC30-50-226

• The Code requires that the pre-screening function be performed by a designee of the local CSB; employees of the BHSA would not & should not qualify
• The definition of Human Services field is not the same as it is in 12VAC30-50-130 and should be revised accordingly.  There also must be a provision for the “grandfathering” of all who have been hired under the current definitions. 

 12VAC30-60-5

• All new language about audit requirements; adds language which includes the following requirement “... DBHDS license shall be a full annual, triennial or conditional license.”  Insert a comma after the word “full” to accommodate licenses issued for less than three, but more than one year.

 12VAC30-60-61

• IIH Assessments can no longer be performed by an LMHP Supervisee or Resident; this is unnecessarily restrictive.
• In C. 5. the term “duplicated” is too vague and is, therefore, open to interpretation by auditors.  If what is meant is the progress notes should not be templates used for all or most participants, then that is how it should be described. 
• In C. 16. Add “If Case Management services pursuant to 12VAC30-50-420 or 430 are not being received, it is critical that the IIH provider link the individual and/or his parent or guardian with services and supports necessary to maintain or improve the stability of the home and family.