To: Behavioral health providers transitioning to the behavioral health entity license (specifically CMHCs)
From: Kara Johnson-Hufford, Associate Director, Health Facilities and Emergency Medical Services Division
Date: September 7, 2021
It has come to the Department’s attention that, due to the need to provide services remotely instead of in-person during the ongoing Covid-19 pandemic, Community Mental Health Centers may have locations in which in-person services are not currently being provided. Questions have come up regarding whether those locations should be included in the application for the BHE license as a physical location. After reviewing the licensing rules in 6 CCR 1011-1, Chapter 2, General Licensure, and 6 CCR 1011-1, Chapter 3, Behavioral Health Entities, the Department has determined that providers have discretion in choosing whether to include the location(s) in their application, based on what is most appropriate for their own situation and their own business needs.
The attached memo addresses several considerations related to the decision to include or not such locations within a Behavioral Health Entity (BHE) license. Please note that the considerations detailed within the memo only to CDPHE facility licensing, and do not take into consideration non-licensing issues, including but not limited to contractual and/or reimbursement issues, staff safety and/or worker’s compensation issues, or rental agreement and/or premises liability insurance.
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