Thank you for the opportunity to express concerns and suggestions related to the redesign of many CMHR services. 

Requiring a LMHP to complete the assessment, develop the treatment plans, complete quarterly reviews of the TX plans, and also provide direct services while result in an increased turnover rate.  The additional responsibilities will become overwhelming to our LMHP staff and lead to burn out.  Due to workforce shortages, CSBs are already challenged with hiring and retaining staff.  If these changes are made, CSBs are going to need additional LMHP staff.  CSBs will experience an increase in salary expenses as a result of hiring more LMHP level staff.

There is a benefit to the LMHP completing the assessment (CNA).  When the assessment is completed by a LMHP, it can be utilized by other program areas.  Currently, the QMHP level staff are developing the TX plans, conducting the reviews, and providing direct services.  These responsibilities should remain with the QMHP role.  The QMHP will most likely spend the most time with the consumer.  The QMHP will have the most accurate knowledge of the consumer’s needs, desired goals, and strengths to develop a person-centered TX plan.    

Introducing another assessment tool to staff will lead to many challenges.  Staff have many concerns about the amount of documentation that is required currently to meet both DMAS, MCOs, and licensure regulations.   One of the retention efforts, was to reduce documentation when possible.  STEP-VA (DBHDS) already requires the DLA-20 to be used by CSBs.  The DLA-20 helps to assess the consumer’s level of functioning.  The results of the assessment tool would support the criteria for SMI or SED.  Instead of using the CANS/ANSA, could the DLA-20 in conjunction with the CNA also met the recommendation of a standardized assessment. The CANS/ANSA is completed in another database.  The DLA-20 is completed within the CSBs electronic health records.  Data is already being collected directly from the EHR.

 Peer recovery support services is an EBP and is proven to be an effective component of treatment.  Peer services can be provided to both the youth and adult population. Peer recovery support services are included in STEP-VA but not included in the CPST model.  There are not any services the CPRS staff are able to provide.  To include Peer services would be very beneficial to the consumers. 

The Case Management service is the hub of a consumer’s mental and physical health care.  Case Management is very beneficial to consumers and providers.  Case Management service includes care coordination between all providers linked to the consumer.  This service ensure that all providers have up-to-date, accurate information which is necessary to deliver effective treatment and services to the consumer.  Case management arranges, links and monitors the services the consumer needs to improve their level of functioning in the community.  There are many times case management is the only service a consumer is engaging in even when there is a need for additional supports.   To remove the ability for a case manager to provide brief counseling, psychoeducation, community integration, and the option to make collateral contacts would be a disadvantage to the consumer.  Due to waitlists and limited resources in the community, the consumer will not have their immediate needs met.  There are also times, the consumer refuses to participate in multiple services or speak to different providers.  Case management has been able to fill in the gaps until the consumer is ready to purse the appropriate level of care or it becomes available. The current case management model allows for staff to help the consumer maintain their mental stability in the community, even when the consumer is not in crisis or have an immediate need but to serve as a prevention measure.  Some consumers may need supports long-term to remain independent in the community.

Redesigning services has its benefits and challenges.  Making changes to so many service areas at one time is going to be very overwhelming to consumers, CSBs, and other providers.  It will also be costly.  Communities do not have all the resources needed to provide the quantity of CPST services that will be needed, if case management becomes limited.