The Mississippi Division of Medicaid’s policy for psychiatric residential treatment facilities (PRTFs) is open for comment. Anyone, including families of children who have been in PRTFs, can comment on the policy or make suggestions about it.
According to the Mississippi State Department of Health (page 2), “Psychiatric Residential Treatment Facility” means any non-hospital establishment with permanent facilities which provides a twenty-four (24) hour program of care by qualified therapists …… for emotionally disturbed children and adolescents ….who are not in an acute phase of illness requiring the services of a psychiatric hospital, and are in need of such restorative treatment services.”
As of February 2019, these are the Mississippi PRTFs that can receive Medicaid reimbursement: CARES Center, The Crossings, Crossroads, Diamond Grove, Millcreek (Magee), Millcreek (Pontotoc), Parkwood PRTF, Specialized Treatment Facility, and Youth Villages. Canopy Cove Eating Disorder Treatment Center and Timber Ridge Ranch are out-of-state PRTFs that can be accessed if recommended by the State Level Case Review team.
The PRTF policy that is open for comment is about treatment planning. Pages 1-3 of the document are the new proposed policy. Pages 4-6 are what Medicaid proposes to delete from (the sentences that are crossed out) and add to (the underlined sentences) current policy. Medicaid describes these as “minor changes,” including changes to make the policy consistent with the Mississippi State Department of Health Minimum Standards for PRTFs.
You can comment about the proposed changes or the policy in general. Remember, if your child has been in a PRTF, you know something very important that no one else knows: you know what did and did not help your child. Sharing your thoughts about how PRTFs can be most helpful to children and families gives Medicaid valuable information to make good decisions.
Families as Allies has just started reviewing the policy but will likely comment on these points, which we believe would make the policy more consistent with state law about the system of care, family-driven practice, wraparound care coordination and Making a Plan (MAP) teams:
- 4.9.A.4 (middle of page 1) – This language: “The treatment plan document must contain evidence of the individual’s and his/her parent or legal guardian’s active participation in the treatment planning/review/revision process,” should be updated to: “The treatment plan document and progress notes must contain evidence that the treatment team actively partners with families and fully includes families in decisions, including by scheduling meetings and calls at times that work for families and asking families what types of supports would be most helpful to them and implementing those supports.”
- 4.9.C.8. (b) (bottom of page 2) – This language: “If special procedures become necessary, the treatment plan must be amended or modified within one (1) working day of the first incident to reflect the use of the least restrictive necessary measures. The effectiveness or ineffectiveness of interventions must be evaluated and incorporated into the individual’s treatment plan to be used as a basis for future interventions” should be updated to clarify that the interventions in the treatment plan are those intended to support the child in managing behavior, not the special procedures themselves. Special procedures are not treatment interventions.
- 4.9.C.10 (middle of page 3) – This language: “Identification of goals, objectives and treatment strategies for the family as well as the individual, and identification of the clinician responsible for family treatment. If a geographically distant therapist will be utilized, this must be specified in the treatment plan,” should be deleted and replaced with language that requires and reflects a family-driven approach and making the family aware of wraparound care coordination. For example: “The responsible clinician regularly contacts the family to learn more about their goals, needs and input for their child and supports the family in reaching the goals that are important to them. The treatment team ensures the family knows about wraparound care coordination and facilitates the family learning about wraparound facilitation that is available in their area via their local Making a Plan (MAP) team.”
- 4.9.C.11 (c) (middle of page 6) – This language: “No later than seven (7) days prior to discharge, the discharge plan must also include an aftercare plan that addresses coordination of family, school/vocational and community resources, including recommendations and/or arrangements for further treatment, to ensure continuity of care for the individual,” should be updated to say: “No later than seven (7) days prior to discharge, the discharge plan must also include an aftercare plan that addresses coordination through the local Making A Plan team, of family, school/vocational and community resources, including recommendations and/or arrangements for further treatment, to ensure continuity of care for the individual. Coordination with the local MAP team should begin at admission to ensure that the MAP team can function as the single point of entry and re-entry as designated in state law.”
Public comments are due by March 18, 2022. You can address them to Drew Snyder, Director, Division of Medicaid, DOMPolicy@medicaid.ms.gov or Office of the Governor, Division of Medicaid 550 High Street, Suite 1000 Jackson, MS 39201. No specific format is required. If you would like additional information about this policy or about commenting on it, contact (601) 359-3984 or DOMPolicy@medicaid.ms.gov.
