Physician Direction of Mental Health Clinics

The requirement (chapter IV pages 32 – 33) 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.  The reimbursement rate for outpatient therapy is one of the lowest rates for all services, and  the provider must be a licensed clinical professional (or staff working on licensure with weekly supervision by a licensed staff).  This low reimbursement rate for licensed staff is already a burden for providing therapy services.  Fiscal challenges exist without the addition of financially supporting the requirement of a physician to be part of the process (including conducting a face to face interview) for everyone receiving outpatient therapy.  FY 18 we served over 325 children/adolescents with mental health diagnoses through outpatient therapy services (assessment, individual, and/or family therapy).  Of those served, approximately 90% were Medicaid customers.   If these guidelines become effective, I’m uncertain if we will be able to provide outpatient therapy; and unfortunately, there are few private providers in our rural area.  I am concerned therapy will no longer be available for Medicaid recipients in rural Southwest Virginia.  We will need a list of local providers who will meet these new requirements to assist with referrals if they become effective.  Currently, we coordinate services with Primary Care Providers, and refer therapy cases in need of medical assessment / care to physicians or medical providers as part of the treatment process.  We have several medical providers that refer their patients to us for treatment while they provide mental health medications. If a regular Family Nurse Practitioner could provide the oversight and complete the face to face interview (and other requirements) in the place of a physician; it would cause a fiscal burden, but improve the likelihood that providers continue to offer these needed services. Please reconsider the requirement to have physicians direct outpatient therapy services.