To what degree has VDOE been engaged in the proposed changes as the new requirements will have significant limitations on the availability of staff at the school site based on the proposed allowable units per week and per month? 

The medical necessity criteria is extensive and complex – leading the service to unintentionally create barriers to access.  The layers of requirements also pose equity issues as there are multiple requirements from urban school districts and caregivers who are navigating significant and complex challenges associated high levels of economic and social needs in very high-stress environments.  In urban areas with poor social determinants of health including poverty, community violence, limited educational support and limited to no family support, students heavily rely on TDT, and will do the same for CPST, to help them be successful in the school setting.  The aforementioned challenges may require long-term supports and treatment to help them cope in their school setting. Please consider minimizing the medical necessity criteria for equitable and timely access.

Section 4 Program Oversight

Heavy reliance on LMHP staff.  There is a current workforce shortage for licensed staff in Virginia and beyond.  Please reconsider the amount of oversight and involvement requirements of LMHPs such as attendance of 504 and IEP meetings, and signing off on ISPs.

Section 5.3 Crisis Support – Requires 24/7 support be available however the rate does not support the cost to have a LMHP or QMHP on-call.  The maximum of 7-8 allowable hours (for Tier 2 if approved by the MCO) per week, will not be sufficient in an instructional setting in addition to providing crisis support that may happen in evenings, weekends and holidays. Please consider removing the requirement of 24/7 crisis support from this service OR offer more billable hours.

5.3.1.1 Preventative and Recovery Strategies

Practice and rehearsal of self-initiated crisis contact into restorative life skills training and psychotherapy requires time.  If the weekly allowable units of 8 hours per week remains, there is not sufficient time to meet with the student to engage in rehabilitative skills practice, engage in psychotherapy, meet with school personnel, attend 504 or IEP or disciplinary meetings as scheduled, meet with caregivers, respond to crises as needed, intervene when the student displays disruptive behaviors in the classroom and teach emotional regulation in vivo.  This is not possible and not sustainable for the program.  Please reconsider the allowable units for this service as the limited amount does not support a sustainable service.