To Whom It May Concern, 

I have been working as a provider for nearly 8 years. I started off working with clients and familiies recieving Intensive In home services and now work in an agency that provides IIH among other programs. As a provider of community mental health services I have concerns about the proposed regulation changes pertaining to Intensive In Home Services.  I am appaulled at the idea of depending on “care coordination”  from the local community service boards. In my professional experience, I have come to realize that Virginia's CSBs are already overburdened with clients and currently have been unable to meet the high demands for case management services for our underserved populations. To schedule a case management appointment to date takes 1 month or more. All of the client's we work with already report unable to meet effectively with their CSB case managers. I have even been told by CSB professionals that community based programs can do more. The CSBs are strained and as a result quality case management services are not being provided to the capacity our client's need them to be. Shifting care coordiantion, case management from IIH solely to CSBs will have adverse effects in the long run. 

It is safe to say that 90% of the clients receiving IIH services come from families who are on the poverty line with limited resources (financial, health, housing,etc.). Most often, IIH clients reside in chaotic home environments surroung by drugs and violence. At times these risk factors contribute to their inability to successfully follow through with scheduled in home sessions. This proposed change will only further impede their ability to schedule and maintain much needed ongoing case management appointments in an outpatient setting. Most of our families do not have reliable transportation, most do no know how to navigate a bus line, most are unable to cope with their current mental health issues to even begin to try and track appointments, etc. IIH providers are able to assist when these instances occur. CSB do no have the capacity to be flexible enough in changing appointments, coordinating transportation, calling and reminding clients. 

The proposed changes are inevitably going to cause a further gap in services. Are we now okay with a case mangement appointment being scheduled 2-3 months out when a family is in need with presenting problems at their time of assessment??? Are we now okay with clients mental health issues deteriorating because they can not focus on practicing coping skills when their basic needs are not met because the CSB case managers are overworked and are not following up as they should???

Working in the a social work driven agency we believe wholeheartedly in the concept "person in environment." The person-in-environment perspective in social work is a practice-guiding principle that highlights the importance of understanding an individual and individual behavior in light of the environmental contexts in which that person lives and acts. The perspective has historical roots in the profession, starting with early debates over the proper attention to be given to individual or environmental change. IIH providers have dedicated their profeessional to providing this proper attentions. Please do not take this away!!!