​CalAIM Behavioral Health Initiative Frequently Asked Questions

Do the changes to assessment timelines for SMHS impact CANS and PSC-35 requirements? What about the Adult Needs and Strengths Assessment (ANSA) (for adults)?

Reference BHIN 22-019

No, the CANS and PSC-35 requirements have not changed. DHCS does not require completion of the ANSA for adults.

Can providers add problems to the problem list that are not diagnoses? Additionally, are the progress note requirements stated in BHIN 22-019 what is minimally required by DHCS?

Reference BHIN 22-019

Yes, providers can add problems to the problem list that are not diagnoses. The problem list should reflect the client's current presentation and unique needs and should include a ICD-10 CM code for each problem identified.  BHIN 22-019, page 6, lists the requirements for SMHS, DMC, and DMC-ODS problem lists. Yes, the progress note requirements stated in BHIN 22-019 are the minimum requirement.

If MHP providers can now deliver co-occurring treatment and focus on a client's SUD needs as clinically appropriate, does that mean the client's clinical record with the MHP will now be governed by 42 CFR Part 2?

Reference BHIN 22-019

Confidentiality of SUD patient records as required by 42 CFR Part 2 would apply to any records which identify a patient as having or having had an SUD and contain information about the SUD obtained through a federally assisted SUD program. If the SUD information was obtained through the MHP or a SMHS provider, these restrictions would likely not apply.

Does identifying a staff's credential (e.g., LCSW) meet the requirement for "title" of provider in the problem list?

Reference BHIN 22-019

Yes, listing a credential is sufficient.

What type of staff can review and obtain signatures for intake informing materials with beneficiaries? Can an administrative staff complete this task, or does it have to be a clinical staff?

Reference BHIN 22-019

Staff completing this task needing to be trained appropriately. For example, if a client has a question about the consent for services, the staff would need to be able to answer these questions or connect the client to an appropriate person to address their questions.

This question and answer has been transitioned to this FAQ from MHSUDS IN 17-040, which was superseded by BHIN 22-019. 

Are client signatures required for group service progress notes?

Reference BHIN 22-019

No, client signatures are not required for a group service progress note.

Are Medicare requirements being taken into consideration since counties must bill to Medicare first? Do clients who have Medicare and Medi-Cal need treatment plans?

Reference BHIN 22-019

Documentation requirements set forth in BHIN 22-019 do not change or supersede any federal requirements.

Because it is not feasible for all currently opened clients to be transferred to having a problem list, what is DHCS' expectation for when clients who have been opened prior to 7/1/22 get a problem list? 

Reference BHIN 22-019

For beneficiaries that were receiving SMHS prior to July 1, 2022, while a problem list is not required to be created retroactively, a problem list should be developed no later than when the beneficiary receives a subsequent assessment, or when there is a relevant change to a beneficiary condition, whichever comes first.  Likewise, for beneficiaries receiving DMC or DMC-ODS services a problem list should be created no later than when the beneficiary is reassessed because their condition has changed, or when there is a relevant change to a beneficiary's condition, whichever comes first.

Is it advisable for providers to document why a long time, i.e. longer than usual, is taken to complete an assessment?

Reference BHIN 22-019

It is good practice to document the beneficiary's circumstances and the provider's efforts to assess and engage the beneficiary, when applicable.

This question and answer has been transitioned to this FAQ from MHSUDS IN 17-040, which was superseded by BHIN 22-019. 

To reduce documentation time, is it acceptable to use checkboxes except where “narrative" is required?

Reference BHIN 22-019

Checkboxes are allowable as long as the note narrative is individualized, provides sufficient detail to support the service code selected, and all other progress note requirements outlined in BHIN 22-019 are met.

Is claiming documentation time allowable under Care Coordination currently and as of 7/1/2022 with the new documentation requirements?

Reference BHIN 22-019

Yes, BHIN 22-019 did not change this DMC-ODS policy, providers may claim for documentation time for services. Documentation time should be included in the service time. Per BHIN 22-019, “progress notes shall include . . . duration of services, including travel and documentation time." This policy is effective through 6/30/2023 until Payment Reform goes into effect 7/1/2023.

This question and answer has been transitioned to this FAQ from the DMC-ODS FAQ which was previously published in June 2019.

If an MHP has a current assessment within their electronic health record (EHR) that captures all seven (7) SMHS assessment domains, will the MHP be required to re-structure their assessment so it is categorized by the new domains?

Reference BHIN 22-019

Although the order of the seven domains is not specified, the assessment shall capture all of the required seven uniform assessment domains pursuant to BHIN 22-019..

Are the seven (7) domains for a SMHS assessment required for psychiatric diagnostic evaluations?

Reference BHIN 22-019

Yes. The seven standardized assessment domains are required for psychiatric diagnostic evaluations.

Is there still a DMC-ODS requirement to document the diagnosis as a narrative summary based on the DSM-5 criteria?

Reference BHIN 22-019

No, BHIN 22-019 did not retain the requirement to document  a narrative summary in the ASAM assessment; Please see section 3 of BHIN 22-019 for the requirements of the documentation of diagnosis / reason for service encounter in the problem list. ​

​How do Medi-Cal providers reconcile the requirements of BHIN 22-019 with the Alcohol and/or Other Drug (AOD) Program Certification Standards that pertain to treatment plans?

How do Medi-Cal providers that operate adult alcoholism or drug abuse recovery or treatment facilities comply with the requirements of BHIN 22-019?

How may providers document the beneficiary's involvement in the treatment process?