Section 1: Purpose and Authority

1.2

Seeking clarity on if the CANS Lifetime 1.0 will serve as the sole assessment required for services under CPST and CSC. Will the 15-domain Comprehensive Needs Assessment still be required at least annually?

Section 2: The Virginia CANS Lifetime—Overview

2.1

Seeking clarity on how CANS Lifetime Assessment, which serves as the foundational document for Medicaid service authorization and the ISP development, takes into consideration an individual’s choice/preference with regards to the services and goals they wish to work on.

2.3

Concerns exist regarding limitations within defined domains. For example, age 0-5 being identified for preschool/daycare does not encompass those attending public school for kindergarten under age 6. Additionally, not all individuals have completed school by 18 years old; many attend until 21 years old under an IEP.

Section 3: Rating Scales and Action Levels

Seeking clarity on how it is decided when a rating is lowered; who is ultimately responsible for making this determination? Is there a process outlined if there is not agreement in the rating?

3.1

Concerns exist regarding the prescriptive nature of rated scores translating directly into action levels and thus negatively impacting an individual’s ability to self-direct the treatment/ services that they wish to participate in.

Section 4: Provider Certification and Qualifications

Several concerns exist regarding the certification process being unclear and the exam being difficult to pass given the information provided in the training. It is a concern that it can be difficult for even seasoned staff to pass the certification exam, and the exam is different than doing the assessment. Additionally, having to obtain authorization from CSA to take the training makes this a cumbersome and confusing multistep process.

Section 5: CANS Assessment—Policy Requirements

Concerns exist regarding the extensive amount of time staff will have to commit to completing the reassessment at scheduled intervals as well as at qualifying events.

Section 6: Documentation Requirements

6.3

Seeking clarity regarding what will be required of electronic health records being able to interface/communicate with the submission of CANS data. Will EHRs have the option of submitting the data as is done with the EDW or will agencies be required to take additional steps to log into a portal or DMAS-approved electronic documentation system in order to download and submit the CANS data?

Section 7: CANS Service Authorization and Billing

7.2

Concerns exist regarding providers not being paid for the routine periodic reassessments, particularly when taking into consideration the amount of clinical time that completing the CANS will require.

7.3.3

Concerns exist regarding the required service authorization to be in place in order to complete an events-based reassessment in conjuncture with the dictated timeliness requirements in relation to the qualifying event and the reporting of the event to the staff.

Section 8: Domain-Specific Clinical Guidance

Seeking clarity regarding whether the Comprehensive Needs Assessment will continue to be required in addition to the CANS Lifetime as it will require a full explanation within each domain. If so, this presents with concerns for redundancy.

Concerns exist regarding the subjective nature of providing a rating to some of the identified domain areas.

Section 10: Training Resources and                    Technical Assistance

Concerns exist regarding limitations to the CANS training sources and availability for providers to enroll all required staff into as well as pass the training in order to be CANS certified by the required timeline.