Commenter: Mindy Carlin, Virginia Association of Community-Based Providers (VACBP)
Comments on Definitions
The following summarizes feedback regarding the "Definitions" section received from our members since the draft policy was released:
CANS Lifetime Assessment Clarity: Need explicit guidance on which evidence-based practices (EBPs) are required or allowed; uncertainty over whether providers can use alternative EBPs.
Terminology and Compliance Ambiguity: Terms like “affiliated” and “school setting” are unclear, as are expectations for MOUs and their alignment with FERPA/HIPAA.
Supervision Standards: Request clarification on what it means to “address the spiritual needs” of individuals within supervision requirements.
Tele-Supervision and Confidentiality: Recommend updating “face-to-face” and “supervision” definitions to reflect modern tele-supervision practices while ensuring confidentiality safeguards.
Transparency on CANS Lifetime Tool: Stakeholders want to see the actual CANS Lifetime tool and question why it hasn’t been shared publicly.