Comments on the DRAFT Licensing Regulation revisions:

§20 Definitions

1. Definition of “Case management service” or “support coordination service” - “Case Management Service” is a specific service requiring a DBHDS license, 16-001 through 005.“Support coordination service”, however, is often a component of another service as “care coordination” defined and required by DMAS which does not require separate licensing to provide. Please reference DMAS’ definition and description of “Care Coordination” in the CMHRS Provider Manual, Chapter 4, pages 13-14; the description of “care coordination” is the similar to the definition of “case management or support coordination service” defined here by DBHDS.Since “support” is synonymous with “care” in the definition immediately above in §20, including both terms in the same definition implies that “support coordination service” would require a separate license to provide.Was that the intention here?
2. Would recommend adding a definition for “counseling” to align with the DHP and DMAS definitions and regulations.
3. Definition of “Intensive in-home service” – recommend removing “case management” from the definition of IIH.“Case management” was removed as a component of the IIH service by DMAS in January 2015 and replaced with “care coordination”.See DMAS regulations at 12VAC30-50-130.5.b.
4. “Mental Health Community Support Service (MHCSS)” – Reviewing the most recent revision of the DBHDS Service Modification Provider Request form (12/2017), the license code 03-002 for Mental Health Community Support Service has been removed.A specific license/code for Mental Health Skill Building Service has been added, 03-001.Should this definition be replaced/updated to reflect “Mental Health Skill Building Service” now?
5. “Missing” – this definition needs further clarification as it applies to residential versus community-based services, especially now that it is included as a reportable Serious Incident.
6. Recommend providing specific examples of a “Level I Serious Incident”.
7. Definition of a “Level II Serious Incident” – “hospital admission” – needs to be more specifically defined to exclude routine or planned medical services.Maybe should be qualified as hospitalization due to a medical or psychiatric emergency/crisis?

§30. Licenses.

1. B.13 – Recommend changing MHCS to Mental Health Skill Building or adding Mental Health Skill Building since it is now listed separately as a licensed service, 03-001.

§160. Required reporting.

1. More clearly define “a person who is missing” as it relates to a community-based program.
2. More clearly define “hospital admission”.
3. Requiring a root cause analysis for all Serious Incident Levels will create additional administrative burdens on providers.Level I reports would already be reviewed on a quarterly basis and not necessarily require this level of analysis.