The Latest in the Long Line of Added Requirements for DOJ Compliance

June 22, 2020

DBHDS has released a “tool” for Case Managers to use at face-to-face visits (more on that later) to comply with the DOJ Settlement provision V.F.2 to assess conditions, services, risks, whether a change in the ISP was or should be warranted.  In July 2019 the Independent reviewer was satisfied that DBHDS initiatives have improved Case Management functioning and stated that the “Commonwealth will collect data and maintain records to determine the extent to which it is fulfilling the requirements of the newly agree compliance indicators.”  Even with all of the information which is routinely entered into WaMS the last report of the Independent Reviewer said the “Commonwealth has not provided sufficient data, analysis and documentation that aligns with compliance indicators and cannot demonstrate that the indicator requirements and the measures have been achieved.”  It’s all about the data not about the performance!  So, once again . . .

 

The “tool” and all of the attachments are linked below – you will note that remarkably if the CM has a concern they are not directed to the provider for resolution, but rather directly to DBHDS or a Team meeting.

 

On a positive note, VNPP is very pleased to be collaborating with VACSB to develop guidance for dealing with the inevitable conflict between the use of this new tool and the current protocols in place during the state of emergency.  We will share the results of our collaboration by the end of the week!

 

On-Site Visit Tool

 

On-Site Visit Reference Chart

 

Defining Change of Status and ISP Implemented Appropriately

 

Review of the Independent Reviewer’s Reports

 

DRAFT Letter