Below are the Frequently Asked Questions and drafted responses and guidance from DBHDD. These FAQs will ultimately be published on ZenDesk for ongoing easy reference. Before we publish, we want to confirm that the answers make sense and whether any further questions arise.
Please review the below and share with the appropriate members of your agency to ensure the guidance is clear. This document was originally provided to HSP providers in December 2021.
Questions about Enrollment into the Housing Support Specialty Service (HSP)
- What is needed for an individual to be enrolled into Housing Supports by a HSP provider, including documentation?
- Individual must be currently enrolled in the Georgia Housing Voucher Program.
- A verification of diagnosis from within the last 12 months.
- An Individualized Recovery/Resiliency Plan (IRP) updated within the last year.
- ANSA/CANS assessment should be completed within 30 days of enrollment into HSP but it is not needed at time of authorization for the service.
- What documentation needs to be requested from another provider when coordinating around HSP?
- ANSA/CANS or other assessments. Information about their functioning, needs, goals, etc.
- Verification of a current diagnosis. Must be current within last 12 months. GHVP Disability Verification form is permissible if within timeframe.
- Individualized Recovery/Resiliency Plan (IRP) which should include housing goals.
- What if the individual hasn’t been connected to a service provider in some time and all relevant documentation is expired?
- If an individual hasn't been in services with a provider and documentation is out of-date, DBHDD recommends to re-connect the individual to core services.
- Do individuals have to be seen for a "provider intake" for HSP enrollment?
- HSP enrollment is not the same as a typical provider intake process because by the time they are connected to the HSP provider, the individual has typically already undergone intake with a clinical provider where the necessary assessments, diagnosis, and planning should have already occurred.
- HSP providers should seek to avoid any unnecessary duplication of any of these activities.
- Individuals may need to go through an intake process if they are to be reconnected to core services.
- Where should HSP enrollment occur?
- GHVP participants should be met where they are. Individuals should not be asked to come into the agency offices for HSP enrollment.
- Telehealth is acceptable for enrollment when reasonably necessitated. In-person, in-home visits remain required per the service definition.
- Can GHVP participants have two open ECRs at two different CSBs as a result of their enrollment in HSP?
- Yes, so long as the services are different, this does not present a problem. An individual can only be enrolled in Housing Supports with one provider agency.
- A GHVP individual will be enrolled in Housing Supports with an HSP provider and may be in any variety of clinical services with a core provider.
Behavioral Health Assessment (BHA) and ANSA/CANS Questions
- Does an HSP enrollee need a BHA?
- Per Part II of the Provider Manual:
"An initial ANSA/CANS assessment must be completed within the first 30 days of intake into all behavioral health services types, excluding CSC, CSU, and Mobile Crisis Response. Ongoing ANSA/CANS assessments must be completed as demanded by changes with an individual, as needed for reauthorization of services, and upon discharge."
- Is an ANSA/CANS required for the HSP service authorization?
- HSP providers do not need to submit an ANSA/CANS when authorizing the HSP. It is not required for authorization of HSP with ASO. It is optional.
- However, an ANSA/CANS must still be completed within 30 days of enrollment.
- Does the HSP provider need to request the ANSA/CANS from the referring core provider?
- An HSP provider should always request a copy of the latest ANSA/CANS from their clinical provider as part of best practices care coordination.
- For individuals enrolled in core services, they should have a BHA and current IRP and ANSA/CANS that can be shared by the current clinical provider.
- How recent does an ANSA/CANS need to be?
- There is not a defined rate of frequency for completing a new ANSA/CANS for an individual that is currently in services, they should be updated as necessary and appropriate. However, there are events for which one is required. Individuals should have an ANSA/CANS completed within 30 days of enrollment into a behavioral health service per the above guidance.
- What happens when an individual has an old ANSA/CANS?
- A new one should be sought to be completed within 30 days of enrollment, based on above guidance. If an ANSA/CANS has been completed within last 30 days, it meets this requirement and should be requested to have on file.
- Can/should HSP providers conduct BHAs? If yes, in what cases?
- When a HSP referral is made for an individual in services with a core provider, the HSP provider should be speaking to the core service provider first before attempting to conduct any assessments, to avoid duplication.
- HSP providers are allowed to conduct a BHA but staff must be trained to conduct ANSA/CANS. See billing guidance below.
- Is a telehealth BHA allowable?
- Telehealth is allowable for BHAs, whether by qualified staff from an HSP or Core provider.
- What credentials are required for BHA, or an ANSA/CANS?
- The staff must be ANSA/CANS trained.
- Can an HSP provider bill for conducting an ANSA/CANS or other assessment?
- Conducting a Behavioral Health Assessment is not one of the Medicaid billable services under Housing Supports.
- Core service providers can likely bill Medicaid for conducting BHA. Non-core service providers would not be able to bill for this service.
Diagnosis Verification Questions
- Is a diagnosis verification required for enrollment into HSP?
- Yes, a verification of diagnosis is required for enrollment into the HSP service. It must be from within the last 12 months. Verification can take a variety of forms.
- What if the individual doesn’t have any up-to-date diagnosis verification or other paperwork upon engagement via the HSP?
- If an individual has an expired verification of diagnosis and a new diagnostic is ultimately needed, DBHDD recommends the HSP should connect the individual to a clinical provider so that they can be assessed for any available and relevant services, and so their primary IRP can be updated in collaboration with the HSP agency.
- Absence of a verification of diagnosis will not prevent someone from receiving HSP engagement and it becomes the responsibility of the HSP provider to achieve re-connection with a clinical provider. HSP providers are currently fully funded to conduct outreach and engagement with GHVP participants, regardless of their ability to bill Medicaid for a service.
- What are the requirements regarding a verification of diagnosis in the Provider Manual?
- Per Part II of the Provider Manual, “DBHDD specialty providers” which includes HSP providers, can obtain diagnoses from other providers and need only some basic documentation, outlined below:
"DBHDD specialty providers who must obtain diagnoses from external providers (regardless of whether the external provider is a DBHDD provider) must adhere to the basic requirements above; but are not required to provide documentation of a face-to-face clinical assessment, the factors considered and justification used in determining the diagnosis(es), a summary of findings, or any other supporting documentation related to the diagnosis(es) or diagnostic assessment process."
“Documentation of the initial and annually verified diagnosis(es) must:
- Clearly indicate the diagnosis(es);
- Include the following information about the diagnosing practitioner:
- The diagnosing practitioner’s printed name as listed on their license(s); and
- The diagnosing practitioner’s credential(s);
iii. Include the signature of the diagnosing practitioner; and
- Include the date of the diagnosis;"
- What’s an example of a verification of diagnosis that should be readily available?
- The GHVP Disability Verification Form serves as sufficient evidence from the individual’s referring provider, if completed within last 12 months. When an individual is being referred into GHVP, this form must be submitted with the referral so any new referrals should be able to provide this document.
- What if the GHVP Disability Verification form is out-of-date?
- If the GHVP DV Form is out-of-date, other documents can be utilized to verify diagnosis.
- If individual is within the HSP agency's core services, the agency can use access to the individual's Electronic Health Record (EHR) to produce a verification of diagnosis.
- If not within the agency, the form (or something that meets the diagnosis documentation requirements of Part II) will be needed.
- Is a provisional diagnosis allowable?
- No, provisional diagnoses are not permissible.
- Can a HSP provider conduct a diagnostic to achieve a diagnosis verification?
- HSP providers are not required to conduct assessments or diagnostics.
- When an HSP referral is made for an individual in services with a core provider, the HSP provider should be seeking out the core service provider first before attempting to conduct any new assessments, to avoid duplication.
- The HSP provider can conduct a diagnostic if they have the appropriately licensed staff or it can be done by a separate DBHDD core provider.
- If a HSP provider chooses to issue a diagnosis, guidance can be found in Part II of the Provider Manual:
"DBHDD specialty providers who have a diagnosing practitioner on staff who renders diagnoses for individuals served must adhere to the basic requirements above, as well as provide documentation of a face-to-face clinical assessment (telemedicine may be used); but are not required to provide documentation of the factors considered and justification used in determining the diagnosis(es), a summary of findings, or any other supporting documentation related to the diagnosis(es) or diagnostic assessment process."
- Can an HSP provider bill for conducting an assessment or diagnostic?
- Diagnostics and Assessment by HSP providers are not billable via the HSP bundle of services.
- A core provider can still conduct diagnostic or assessments and likely bill Medicaid for it.
- A non-core provider can conduct a diagnosis if they have the appropriately licensed staff and choose to do so but they cannot bill Medicaid for it.
Individualized Recovery/Resiliency Plan Questions
- What are the timeframe requirements around an IRP?
- Per Part II of the Provider Manual:
"The IRP must be reviewed and updated at least annually, and more frequently as may be needed to reflect the individual’s evolving needs and goals. This plan sets forth the course of services by integrating the information gathered from the current assessment, status, functioning, and past treatment history into a clinically sound plan."
- How should HSP providers approach the requirement for each enrollee to have an Individualized Recovery/Resiliency Plan (IRP)?
- Per Part II of the Provider Manual, HSP providers should be involved in the ongoing development and update to the IRP:
"Others who should assist in the development of the IRP are persons who are:
- Significant in the life of the individual and from whom the individual gives consent for input;
- Involved in formal or informal support of the individual and from whom the individual gives consent for input; and
iii. Will deliver the specific services, supports, and treatment identified in the plan."
- HSP providers are not expected to develop IRPs on their own. When a HSP referral is made for an individual in services with a core provider, the HSP provider should be seeking out the individual’s IRP from the core service provider first before attempting to develop a new IRP.
- HSP providers should be developing a Housing Plan with the individual and it should be incorporated into their overarching IRP that should generally live with their primary clinical service provider.
- Can HSP providers develop a new IRP?
- HSP providers are not expected to develop IRPs on their own.
- HSP providers can help develop an IRP if they have the appropriate staff.
- "An individualized resiliency/recovery plan should be developed by the individual with the guidance of an appropriate professional"
- What does an "appropriate professional" mean?
- Can HSP providers bill for developing an IRP under HSP's service array under Medicaid?
- IRP cannot be billed to Medicaid under HS.
- An HSP provider that is also a core service provider can likely bill Medicaid for it.
- Non-core service providers could not bill for this activity under Medicaid.