The CANS must be completed initially and every 12 months.  Will this replace the CNA and annual reassessments and the DLA-20?  Or is this adding another assessment to the list?  Of the 6 other recommended assessments for adults and 15 for youth, DBHDS already requires the Columbia.  This is a significant number of assessments for the individual to experience.  Recommend swapping the CANS for 1 or more other current assessments.  Also, it is problematic that we are commenting on an assessment that we have not seen, haven't assessed the validity, nor know the training requirements to conduct.

 

When completing the initial CANS, the clinician must be knowledgeable about the 4 listed EBPs whether or not they are offered at the CSB in order to refer the individual if appropriate and also be knowledgeable about the availability, waitlist status, and whether the individual's insurance is accepted at services in the geographic area.  This is an undue training and administrative burden.

 

The clinician must notify the individual's MCO about a potential fit w/ an EBP, coordinate that a CANS is not repeated if not necessary, and coordinate on assessments dates.  This is an undue administrative burden.  How and who at the MCO will be notified, and wouldn't most of this be the responsibility of the MCO Care Coordinator?

 

It's confusing to include 3.3.3 Coordinated Specialty Care when it cannot be provided with CPST as stated in 8.2.d Exclusions and Service Limitations.  Is it included because you mean to indicate that if an individual served in CPST experiences first episode psychosis that CPST should end and the individual transferred to CSC? Or do you mean that CSC should be folded into and billed as CPST as applicable?

 

Annual submission of documentation to CEP-VA is an undue administrative burden.  If this includes PHI, then the risk of breaches increases.