The following are comments/concerns regarding the proposed changes/language:

12VAC30-50-226A- The use of the term “certified pre-screener” is a term of art that, in Virginia, is considered to be exclusive to CSB/BHA clinicians who provide emergency services and pre-admission screening for involuntary detention.  Under Virginia Code, no other entity can perform this function.  Suggest the language be amended in each section where it is used to be clear about the entity and the precise function.  Do not use the term “certified pre-screener” unless it is accompanied by the prefix “CSB/BHA”.

12VAC30-50-226A- “Clinical experience”:  Suggest deleting “on a full-time basis” or allow clinical experience to be the “equivalent of” an amount of full-time experience.  Otherwise, the pool of providers is more severely limited than what it is now and recruitment will be affected.  Parents and caregivers, for example, may need to work part-time.

As well, there should be a flexible process remaining in the regulations for approval of an alternate degree.

 12VAC30-50-226A- “ISP”:  Language should be added to reflect person-centeredness and assure that the recipient is part of service planning.

 12VAC30-50-226A-QMHP-A and C”:  Grandfathering and variances, as explained in the general comments, will be critical in retaining staff to provide these services.

 12VAC30-50-226A-Registration: When CSB/BHA clinicians are addressing emergency situations, triage and stabilization should be allowed and followed by a Registration, as explained in our comments above. 

 12VAC30-5-226B1-Service-specific provider assessment:  Please clarify.  Is this the same as a comprehensive assessment?  And should the assessment include specifically the behavioral and primary health needs in “health status”?

 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.  

 12VAC30-50-226B “Intensive Community Treatment”: Licensure through DBHDS for this service is based upon the national PACT model.  We suggest this service remain as it is and that DBHDS issues guidance to CSB/BHAs as to how Licensure requirements will be reconciled with the proposed changes.  Also, VACSB recommends that the language in the current regulation be reworded to more accurately address the clinical profiles of individuals in need of ICT.  Delete the phrase “demonstrates a resistance to seek out and utilize appropriate treatment options” in Section 4.b. in the current regulations. Instead, insert the phrase “when services that are far more intensive than outpatient clinic care are required and services in the home and the community are more likely to be successful”.

 12VAC-50-130 - Activities of Daily Living:  Proposed regulations state “Activities of daily living means personal care activities and includes bathing, dressing, transferring, toileting, feeding, and eating.”  VACSB suggests that the list of allowable activities of daily living should be expanded to include shopping, budgeting, meal planning, and medication management, all of which are essential activities for individuals with Serious Mental Illness. As well, include the language for Instrumental Activity of Daily Living (IADLs).

 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.

12VAC30-60-143-PCP Notification:  With language that assures recipient’s consent to the notification, VACSB fully supports this provision.