Southside Behavioral Health appreciates the opportunity to provide comments on the draft Mental Health Case Management (H0023) regulations. We support DBHDS’ efforts to clarify expectations, strengthen accountability, and improve consistency across the Commonwealth. However, we respectfully submit the following concerns and recommendations to ensure these regulations are realistic, equitable, and client-centered for Community Services Boards (CSBs), particularly in rural regions such as ours. While we support the intent to improve accountability and consistency, the draft regulations do not clearly outline the problem they aim to solve or present data supporting the proposed structure. We encourage DMAS and DBHDS to clarify the intended outcomes and how these changes will improve service quality or client experience.
Concern:
While the draft outlines functional impairment domains and examples, it does not establish a validated tool or standardized scoring system. This creates risk of inconsistency across providers, subjectivity in classification, and challenges during utilization review. Individual needs often fluctuate due to changes in health, housing, or support systems. The current structure assumes static categories that do not reflect this fluidity. We recommend flexibility in documentation requirements to avoid unnecessary reclassification and disruption of services.
Recommendation:
Adopt or endorse a validated statewide tool to guide intensity level determination.
Establish a standardized protocol with required documentation points to ensure uniformity across CSBs.
Require inter-rater reliability training to promote consistency and fairness in client categorization.
Concern:
The phrase “History of falling through cracks of service systems” in the high-intensity category is stigmatizing and unprofessional. It implies fault lies with the individual rather than with systemic barriers.
Recommendation:
Replace with: “History of unmet service needs due to barriers in system navigation or coordination.”
This wording more accurately reflects systemic issues while maintaining dignity and respect for clients.
Concern:
The draft regulations outline extensive staff qualification requirements but do not include a structured approach for training, competency development, or retention. Effective case management requires ongoing skill-building in areas such as service coordination, documentation, and system navigation. Without standardized training and opportunities for professional growth, CSBs risk variability in service quality and increased staff turnover.
Recommendation:
Establish a DBHDS-approved training and certification program for Mental Health Case Management staff, including initial and annual competency requirements.
Provide funding or access to statewide training resources to ensure consistent knowledge and skill development across all CSBs.
Implement ongoing professional development opportunities to promote staff retention and reinforce best practices in case management.
Encourage DBHDS to recognize and track continuing education as a quality metric that supports workforce stability and service excellence.
Concern:
The requirement to submit a registration within one business day of admission creates administrative challenges for rural providers with limited staff or technology barriers. Failure to meet the deadline changes the service start date, resulting in potential revenue loss and service disruption.
Recommendation:
Extend the registration window to three business days.
Permit retroactive corrections when documentation supports timely service initiation.
Concern:
The limitation of billing case management during only two non-consecutive pre-discharge periods per year may not reflect the realities of individuals with recurring hospitalizations. These individuals often require ongoing community case management to reduce readmission risk.
Recommendation:
Increase flexibility to allow billing for additional periods when clinically justified.
Provide clear guidance on documenting case management roles without duplicating institutional discharge planning.
Thank you for the opportunity to comment. We look forward to collaborating with DBHDS on finalizing regulations that strengthen quality, equity, and access across Virginia’s behavioral health system.