Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Amount, Duration, and Scope of Medical and Remedial Care and Services [12 VAC 30 ‑ 50]
Action Mental Health Skill-building Services
Stage Proposed
Comment Period Ended on 10/23/2015
Previous Comment     Next Comment     Back to List of Comments
10/20/15  2:01 pm
Commenter: Heather Hamed-Moore

Proposed regulation changes

Requiring LMHP or LMHP-like staff to complete ISP's will not only encourage unethical behavior, but will hinder agencies that strive to provide high quality, ethical mental health services as the cost incurred to pay staff with such credentials will increase, which may in turn, decrease care in other areas of services.  The work involved in creating an ISP does not contribute to hours needed to obtain licensure and therefore would make obtaining LMHP staff more difficult due to already limited access to such individuals.  ISP's are designed to be person centered, which also makes it more difficult for an LMHP staff to complete as the LMHP is currently only present with the individual for a limited amount of time and cannot ensure that upon creation of the ISP, the client will be willing to participate in all areas of the ISP, which places the ISP at risk of taking longer to be approved and signed upon by both the client and the LMHP staff.

In regard to requiring an authorization for Crisis Stabilization Services, I believe that this change would limit individuals with serious needs from accessing services in order to avoid hospitalization.  If the Crisis Stabilization Service requires an authorization, the individuals will not receive prompt care and could be placed in a more restricted environment, such as hospitalization, which would increase the crisis upon discharge from hospitalization.  For a person in a crisis situation, a 2-5 day wait for authorization for Crisis Stabilization Services could be the difference between life or death.

Thank you for your time and consideration.

CommentID: 42243