Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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10/7/17  10:32 am
Commenter: Robert Miller, Sundog Psychology LLC

Chapter II Psychiatric Services pages 15-16
 

It has come to my attention that DMAS intends to change regulations to disallow unlicensed providers from providing outpatient services. I am opposed to this proposed change. The change contradicts the DMAS mission statement, which states in part that DMAS strives “…to provide a system of high quality and cost effective health care services…” Unlicensed and well-supervised providers are cost effective and therefore save taxpayers money.  The proposed change also undermines initiatives in the DMAS Strategic Plan. For example, the Strategic Plan makes note of “concern regarding the aging workforce” and how “(p)otential retirements could have a significant impact on the agency’s operations in terms of the loss of experienced managers and other key agency staff.” Unlicensed providers are often entry-level professionals who ultimately seek licensure and therefore move up in the DMAS workforce. It would appear the proposed regulatory change would cut off a potential source of future workers. On a personal note, I have practiced as a counselor and clinical psychologist for 40 years. I began my career as an unlicensed paraprofessional in a social services agency and pursued graduate school while working in programs similar to those supported by DMAS. If I had not had the opportunity to work as an unlicensed supervised provider my career trajectory may have been different.

CommentID: 62901