The Virginia Association of Community Based Providers (VACBP) endorses most all of the extensive and very good comments from the Virginia Association of Community Service Boards (VACSB).  In addition, we would like to emphasize the following:

Chapter IV, p. 62, as proposed, psychiatric physician extenders (psychiatric nurse practitioners/physician assistants), would no longer be able to provide the needed psychiatric assessment required for Crisis Stabilization.  Psychiatrists who take Medicaid are few and far between and Crisis Stabilization is only a two-week program.  As a result, the program would be at risk of becoming obsolete because most providers would not be able to ensure that clients could see a psychiatrist to provide the evaluation.  Most providers use Psychiatric nurse practitioners (overseen by a psychiatrist) to conduct the needed psychiatric/medication evaluation.

Chapter IV, p. 59, as proposed, would limit assistance with medication management which is not sustainable from a workforce standpoint.  We recommend changing to “The LMHP (type) shall provide medication management (as defined) during each assessment event, and the QMHP shall provide support and education for adherence to a medication regimen.”

Chapter IV, p. 46-47, proposes changes that conflict with parity laws.  Should recognize that 1) since a decision that TDT after school program is a separate service from the TDT school program, and 2) that parity laws do not allow time limits on service, the billing for these two services must be "un-bundled.” Currently only three units for TDT can be collectively billed per day by all involved providers, regardless if the child is in both services.  This would limit availability of the beneficial after school service. 

Chapter IV, p. 57, and p. 59, as proposed, would eliminate services from QMHP’s for CI and ICT.  This would reduce access to the service due to the lack of availability of LMHPs and LMHP-types in the workforce.

Chapter IV, p. 30, as proposed, defines IIH as an intensive therapeutic service and reference is made to required individual and family counseling by a LMHP, LMHP-R, LMHP-RP, or LMHP-S.  We support the frequency of counseling as determined by the licensed professional.  We also recommend reference to the QMHP as in Chapter II, p. 15.

In future revisions of regulations and guidance documents, as the service delivery system changes from fee for service to managed care, and the focus shifts from payment for services to payment for outcomes, the VACBP supports working together to provide more emphasis on reimbursed care coordination efforts and outcomes (value) and less emphasis on restrictive professional qualifications and service definitions.