Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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10/30/19  4:13 pm
Commenter: Carol Layer, Executive Director, Alexandria CSB

Definitions through "Screening"

Full time employee” or “employee” means an employee employed on average at least 30 hours of service per week, or 130 hours of service per month. 

Feedback: It is confusing to define “employee” and “full time employee” synonymously. Agencies employ employees who work fewer than 30 hours per week or 130 hours per month and are still employees

"Initial assessment" means an assessment conducted prior to or at admission to determine whether the individual meets the service's admission criteria; what the individual's immediate service, health, and safety needs are; and whether the provider has the capability and staffing to provide the needed services. An assessment is not a service.

Feedback: This is an extremely confusing term as used here.  Perhaps consider calling it “eligibility screening” if that is the intended meaning.  An assessment is commonly considered a clinical evaluation and most definitely is a service, often billable.

Social detoxification service" means providing nonmedical supervised care for the individual's natural process of withdrawal from use of alcohol or other drugs.

 Feedback: The elimination of the licensing category of non-medical detox/ social detox has resulted in elimination of an essential component in the Alexandria continuum of care for individuals with SUD.  Social detox is an ASAM-defined level of care that can provide a drug and alcohol-free environment with safety, stability, and supervision for individuals in early stages of recovery who do not need or want a medical environment or use of medication to safely eliminate or reduce the effects of alcohol or other drugs. A social detox program that properly assesses and monitors individuals and can refer clients for timely and appropriate medical intervention when needed is an appropriate level of care for many individuals with SUD and the removal of the licensing category runs contrary to the goal of providing cost-effective community care of the lowest appropriate level of intervention in the least restrictive environment.  The medical detoxification standards are significantly more costly to operate and staff and there is not commensurate reimbursement for this higher level of care by DMAS or other payors.  The levels of care defined by licensing should be compatible with ASAM levels of care and congruent with DMAS definitions and reimbursement structure.


Mental Health Community Support Service Skill Building" or "MHCSS


Feedback: Consider aligning the acronym with the name of the service to improve clarity.  Perhaps MHSB instead of MHSS.

"Screening" means the process or procedure for determining whether the individual meets the minimum criteria for admission assessment

Feedback: Definition of “assessment” “initial assessment” and definition for “screening” are indistinct. Unclear differentiation.





CommentID: 76774