Virginia Regulatory Town Hall
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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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10/5/17  6:19 pm
Commenter: Amanda N. Trent, PsyD, LCP, Sexual Assault Resource Agency

Proposed DMAS changes to requirements for providers of mental health counseling
 

I am surprised by the proposition of such a change in the regulations, as individuals who are on Medicaid have been well-served through MANY programs, practices, and offices by residents in counseling and supervisees in social work.  I wonder if Medicaid makes a similar distinction between medical residents and licensed physicians?  I wonder what the benefit is in limiting providers?

As many professionals and residents have stated in other comments, providing mental health services while under supervision is part of the training process and development of therapists and social workers.  This is the case in the health care world as well.  In my present position and in past positions, I have overseen the training and supervision of trainees in social work, counseling, and psychology.  I would say that individuals who receive services from a resident in training likely are getting even better care than normal, as they have the benefit of at least two mental health professionals considering the circumstances of their case,  and the supervisor wants adequate care given since it's their license on the line.  Also, residents under supervision can also get group supervision with classmates, a professor, or their coworkers.  These individuals have already completed an internship or two by this time and are competent to provide services with oversight.  Competence or quality of care should not be the concern.

The reality of reimbursement rate, the high rates of no shows, and the inability to charge a no show fee make it untenable for most solo or group providers to have more than a small percentage of Medicaid slots.  Until those realities change, again, it is ill-advised to restrict residents/supervisees from providing care to this population.

The need to great, and the amount of available providers is not commensurate.  This change would negatively impact the lower income communities in Virginia, the mental health professionals, and the students who are attempting to gain their licensure.  It also will over burden existing safety nets.  Any concerns that DMAS has identified should be problem solved in another way.

Amanda N. Trent, Psy.D.

Licensed Clinical Psychologist

Clinical Director, SARA

Charlottesville, VA

 

CommentID: 62882