Possible Agency Level Requirements

All agencies shall be accredited within 24 months of the approval of the State Plan or within 24 months of establishment of a new agency by the Council on Accreditation, The Joint Commission, DNV Healthcare, or the Commission on Accreditation of Rehabilitation Facilities. Certification/accreditation shall be initiated and submitted to DMAS during enrollment or within 24 months if the agency is new. $10,000 for costs for this requirement is typically added to rates.

Requiring an agency, that has met all DBHDS standards, to get accredited is counterproductive in filling the gaps in Virginia’s broken mental health system.  Virginia has a shortage of providers and not a superabundance of them.  Is DMAS not aware of the high threshold to meet licensing standards along with the enormous difficulty of agencies initially getting licensed?  Or the constant audits that DBHDS conducts on its licensed agencies to ensure adherence to such standards?  Our agency has been licensed for going on a decade and we’ve worked relentlessly to never receive one inspection infraction.  And now the state is proposing that we spend thousands of dollars to get accredited?  Is it not enough that we adhere to all DBHDS and Human Rights requirements as outlined by the state?  A possible solution to this would be to only add this requirement to those agencies that have constant inspection violations and/or receive provisional licenses.

Caseload limits for each staff level, including across agencies (i.e., licensed individual’s caseload is counted across all agencies where employed).

Caseload limits is problematic for some programs such as Therapeutic Day Treatment and let’s not forget that it was attempted before.  For example, our middle school staff typically maintain a caseload of 10-12 in order for the agency to maintain competitive salaries.  Although this caseload may seem high, they typically only work with 6-8 children daily for several reasons (e.g., sick, suspensions, probation appointments, limited SA approvals, etc.).  If the state is adamant on implementing such requirements, then they need to allow for such reasons and increase prospective caseload limits to 12 or more.  The other solution would be to drastically increase reimbursement rates.  The state must also realize that in order for agencies to retain staff we must pay our staff for when the school isn’t in session.  Putting additional caseload restrictions in place when it’s already difficult to turn a profit will only harm such programs and make it challenging to retain qualified clinicians.