Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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5/31/18  10:10 am
Commenter: Joanna Wise Barnes; ServiceSource, Inc.

2018 Person Centered ISP Guidance

Thank you to the DBHDS staff members who drafted and sought public comments on this document.  The expectations contained in it will be familiar to those who have worked in the field and completed required documentation for some years.  The clarity and examples are appreciated.  Here are our requests:  To complete the process of clarifying ISP expectations, we ask that DBHDS create an ISP template.  The quarterly review template which DBHDS provided and made optional in April 2018 helped providers to understand the minimum amount of information required in the quarterly review.  The certainty of knowing that both DMAS as well as all Offices within DBHDS approved the quarterly review template allowed providers to implement it without fear of negative reviews by external regulatory bodies.  We request a similar template for the ISP - one which contains the minimum amount of information required, approved by all of DBHDS and DMAS.  On page 9 of the draft ISP guidance document, the last paragraph describes support instructions, noting, and data collection.  We also request a template for daily notes to accompany the ISP template.  We would like to have specific information about whether daily notes should be limited to data and other information about support activities related to ISP outcomes, or whether the daily notes must also contain information about general supports throughout the service period, to justify the hours/units billed under the ISP.  One Qlarant reviewer recommended that daily notes could be limited to documenting support activities, but without DBHDS approval of that approach we cannot use it.  In summary, we appreciate the quarterly review template provided and request that ISP and daily note templates be provided as well, and that they similarly include the minimum information required for documentation.  


CommentID: 65351