Review of ISP – Regulatory Town Hall proposed changes indicate that a review of the ISP must occur with the individual quarterly and that documentation of this review must be in the record within 15 days of the review [12 VAC30-50-226 (A)]. However, the documentation is unclear as to which services this regulation applies as one section defines mental health services as including the following: day treatment/partial hospitalization, psychosocial rehabilitation, crisis services, intensive community treatment (ICT), and mental health skill building {12 VAC30-50-226(B)] and another section does not define what services are covered {12 VAC30-60-143(A)} and in fact, removes the prior reference to services covered by this section.

Furthermore, the regulations will need to clearly indicate if the client's signature is required on the quarterly review of the ISP only for MHSS [12 VAC30-60-143 (I)(2)]or if client signatures are required on the quarterly ISP review for other services that may also fall under this new regulation allowing 15 days to complete the documentation in the client record [12 VAC30-60-143 (B)(7)(c)].

Magellan representatives had responded initially indicating that the documentation is required to be in the client record for MHSS only but then indicated on a later weekly provider call that it applies to all CMHR services, which would also include SA services, etc.

Note: The concern is not whether a quarterly review of the ISP is required but (1) to which programs the ability to have documentation present in the record within 15 days of the date of the review applies and (2) for which services the client's signature is required on the quarterly review of the ISP.