July 26, 2019
There have been two communiques from DBHDS about items to be posted on the Townhall Website for public comment; DBHDS does an excellent job of informing the provider community as soon as something has been approved for posting for comment – and we thank them for that! The technology, however, lags a bit behind. Items are not actually visible on Townhall until the date they are actually posted in public view. The Guidance Documents (see post
of earlier this week) will be available on 5 August; the proposed fast track regulations which were the result of a VNPP legislative initiative will be available in a month or so (we will let you know!).
Next week we will attend:
- Behavioral Health Redesign Steering Committee
- Follow-up on the Rebase vs Refresh Rates Discussion, and
- Meeting re Barrier Crimes
All leading to legislative initiatives or discussions in the upcoming Session.
And we continue to work on issues related to TDT especially where the limitations of the number of units approved are putting the child at risk, During the course of a recent discussion with the Plans the following comments stood out. In order to ensure that continued stay (i.e., extended time in a particular service) is understood as medically necessary, the provider must “create the picture of risk.” This is probably different that the current approach of many, but might help providers in their thinking about how to tell the true story.
We also had the second meeting to talk about the significant burden in managing the demands of the MCOs by DD Residential providers; while progress may appear slow, we are thrilled with a couple of the ideas being discussed. For example, DMAS will provide (probably on a quarterly basis) a spreadsheet that will allow the Plans to identify which members are receiving Residential services. This should allow the Plans to respond more appropriately and minimize the time it takes to explain who you are and what you do! Yet to be resolved is the issue of what information can be shared and when the MCO can/will talk to the Residential provider if the individual is not able to have their own conversation.