Psychiatric Services Manual; Chapter IV, under the section for outpatient services (pages 31 - 39); page 32 starts the changes with "Physician Direction of Mental Health Clinic" he majority of the guidelines are outlined on page 33.  

I would like to respond to the noted above changes in the Manual which affect patients and private providers adversely.

1.The notices were not posted in a timely manner for providers to reply to the posting. Few professionals have knowledge of these new changes.

2. The state of Virginia allows licensed providers (LCSW, LPC, etc) the right to practice autonomously. The changes listed forces the provider to have a medical doctor sign off on documents that the provider can legally do on their own in Virginia. Naturally this takes more time and paperwork.

3. The physician must sign off on a referral then it must be authorized by the MCO before the client is seen. Once again this takes time and more red tape for the provide and then the client. What if the client needs mental health assistance asap?

4. The new changes also takes the right to choose a physician from the client. What if the client does not prefer the physician that is affiliated with the mental health practice?

5. These changes affect the rural communities in a negative manner.  In rural Virginia there are very few mental health providers, and this will inhibit them even more by not allowing them the autonomy to practice without medical input on each case.

6. Why have the proposed changes been kept so quiet and the Medicaid recipients not been notified of these changes?

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