1)      RE: Chapter II, Psychiatric Services page 15-16, DMAS requirements regarding provider qualifications for outpatient counseling

If enacted, the proposed changes for Therapeutic Behavioral Services will impact children across the Commonwealth by allowing for fewer mental health services in the short term, and fewer qualified and credentialed counselors in the long term. The direct result will be a decrease in access to mental health services for populations served by DMAS. Today, children and families benefit enormously from quality, child-focused early intervention services to alleviate the life-long effects of adverse childhood events and/or early identification and treatment for mental illness. Removing access to these services will leave our most vulnerable populations more impaired for longer periods of time further impacting their opportunities for successful long-term outcomes. DO NOT approve the proposed changes to provider qualifications for psychiatric services as outlined in Chapter II, pages 15-16 to eliminate the ability of residents in counseling and supervisees in social work to see clients in outpatient counseling settings.

2)      RE: Chapter II, Psychiatric Services, page 15-16, DMAS requirements regarding provider qualifications for outpatient counseling

Outpatient Counseling centers are a critical community resource to provide early identification and intervention for children impacted by behavioral health concerns. License-eligible counselors or social workers under clinical supervision of a licensed counselor or social worker providing outpatient counseling to children is a win-win. Children and families have greater access to services and know they are receiving the highest quality services. Agencies are able to add to the workforce pipeline of counselors and social workers by acting as a training ground. This training ground includes a genuine experience serving a vulnerable and high-risk population. Once trained and licensed, these future counselors and social workers are more likely to choose to work with the population served by DMAS and Medicaid due to the experience they gain during supervision. By eliminating the ability of license-eligible counselors or social workers under supervision to serve Medicaid clients—the workforce pipeline will be squeezed nearly shut in a field that is already in more demand than there is supply of people in the field. DO NOT approve the proposed changes to provider qualifications for psychiatric services as outlined in Chapter II, pages 15-16 to eliminate the ability of residents in counseling and supervisees in social work to see clients in outpatient counseling settings.

3)      RE: Chapter II, Psychiatric Services, page 15-16, DMAS requirements regarding provider qualifications for outpatient counseling

Continued access to robust, community-based services covered by Medicaid in childhood directly reduces costs on other state and community resources. Without this access, the Commonwealth will experience increased costs of incarceration, hospitalization, in-patient services, low graduation rates, teen pregnancy rates, etc.—which are all negative outcomes associated with not receiving intervention for childhood trauma or early onset mental illness. Please keep access as open as it is now for children to receive outpatient mental health services. Even with license-eligible counselors and social workers able to serve Medicaid clients while under supervision, there is a greater demand for services to children than providers are able to meet. Further constraining access is tantamount to creating a community health crisis for families in the Commonwealth. DO NOT approve the proposed changes to provider qualifications for psychiatric services as outlined in Chapter II, pages 15-16 to eliminate the ability of residents in counseling and supervisees in social work to see clients in outpatient counseling settings.