Comment: Chapter IV, pp. 31-34 – Outpatient Psychiatric Services: The requirement for a physician to ‘assume professional responsibility… have a face-to-face visit with the individual, prescribe the type of care provided, and … periodically review the need for continued care’ will have a negative impact regarding outpatient therapy services being available in rural areas of the Commonwealth.  I am concerned individual and family therapy will no longer be available for Medicaid recipients in rural southwest Virginia.  Please reconsider the requirement to have physicians direct outpatient therapy services.  We do coordinate services and refer therapy cases in need of medical assessment and / or services as part of the treatment process.   If a regular Family Nurse Practitioner could provide the oversight and complete the face-to-face assessment and other requirements in the place of a physician, it would improve the likelihood that providers continue to offer these needed services.

Comment: Chapter IV, pp. 32 & 33 – Physician Direction of MH Clinics: The last paragraph on page 32 indicates that there must be direct personal supervision of a physician present whereas the second paragraph on p. 33 indicates that the physician does not have to be on the premises. These two paragraphs needs to be reconciled.

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