|Action||Mental Health Skill-building Services|
|Comment Period||Ended on 10/23/2015|
EVERYONE MUST READ
I recognize as a private provider and someone who has been in the mental health field for over 12 years that costs affect the nature of business in VA.
However, I believe that we have lost site of the true nature of our business and that is helping those with mental illness. We are out here in the trenches supporting those that have been left behind in almost every other aspect of their life. We are in a position where we can change the course of their direction and guide them to their ultimate destination and ultimate potential.
The more recent changes requiring hospitalization from adults with mental illness has made it nearly impossible to provide proactive assistance to individuals. All we can do is provide reactive assistance to these individuals after they have decompensated and are in crisis. Making not only our job 10 x’s harder but also making it even more difficult for the client to get back on their feet, when we could have just assisted with stabilization from the beginning with or without the hospitalization requirement.
The pattern for VA funding has been to make these regulations more and more stringent over the last few years.
What I find hard to believe is that instead of taking a hard look at private sector companies who abuse the privilege of billing for Medicaid funded services and stopping them, or demanding re payment, the decisions made by our government penalize all private providers!
There are horrible unethical private providers!!! There are also outstanding private providers out here doing things ethically and with purpose!!!
Shut down or penalize the providers who are fraudulently billing for services or not providing quality care. I used to worked for an agency that committed millions of dollars’ worth of fraud. I did everything I was supposed to when I discovered fraud within the company. I reported it to Licensure and the Medicaid Fraud Unit with a heavy heart. From there an investigation ensued for over 2 years, part of it under seal. The government then chose not to intervene, and passed the buck to my attorneys. There were not enough people within the company to back the story (hence why they call it a whistleblower suit, qui tam litigation, aka no one else knows because it’s only at the top).
It was explained that basically this wasn’t a case with a large company, more of a mom and pop, so therefore it just wasn’t worth their time anymore. After another almost year of attorney’s stepping into the governments’ shoes to continue to pursue qui tam litigation the case was all of a sudden dismissed sighting because the disclosure statement did not contain enough detail. This was after setting trial dates, and preparing to attend a trial date to compel the other company to produce evidence within a couple of weeks. While a very detailed disclosure statement was provided, the THOUSANDS of documents were not able to be presented at that point in litigation. Therefore, millions of dollars walked out the door. I used the system provided to me. I did what was ethically sound.
And for that I am repaid by now worrying that my now business will be greatly affected by rate cuts, qualification changes, and more upheaval to the delivery of Mental Health Skills Building Services.
In addition, let's have Licensure regulations and expectations that are the same across the board for ALL private providers. On paper it may appear that way, but each Licensure Specialist has their own requests and requirements and each private provider is at their beck and call in order to continue to receive a license in good standing.
It is inconceivable that the Community Service Boards can provide the needed services at the rate and frequencies needed by these mentally ill individuals. I have spoken to clients who have utilized CSB services and the response is always the same. The staff come once a week to check on them, they don’t know who their Case Manager is because they haven’t seen or heard from them in so long, the waiting list is over a month long, they are not accepting new patients for psychotropic medications, and on and on. They mean well, but it's just inconceivable to expect them to be able to manage it all.
A man called my company on the phone in crisis and I was able to verify his insurance, verify he met all the Medicaid criteria for services, and then send an Intake Specialist and Staff member out to the house to conduct the intake assessment, staying on the phone with him until they arrived. Then from there he was able to receive 1:1 direct care from a qualified staff member 3-4 times per week.
We are the ones who provide the reports to the CSB for their files and to count as their contact. We do all the ground work and keep these individuals afloat.
Virginia we have to do better!!!! Stop this madness!!! Please think about who you will effect before making more changes!! Address the real problems!!!
I also support the VACBP comments to the proposed Mental Health Skill Building Changes:
Regarding the proposed regulation which states that LMHP, LMHP- Supervisee, or LMHP- resident shall complete, sign and date an ISP:
In order for providers to have an LMHP/LMHP-like staff member to complete ISP’s, additional staff will need to be hired.
This approach to writing the ISP’s seems contrary to current trends.
Regarding the proposed regulation requiring an authorization for Crisis Intervention and Crisis Stabilization:
Regarding the proposed regulation that Service Specific Provider Intakes (SSPI’s) shall be “repeated” for all individuals who have received at least six months of MHSS to determine the continued need for the service:
Regarding the proposed regulation on the number of days per week and hours per week required to carry out the goals in the ISP:
Regarding the deletion of the change in the billing unit structure that was formerly mentioned in the proposed regulations:
Regarding the proposed change in which Non-Residential Crisis Stabilization may be used as a higher level of care in the consideration of MHSS eligibility criteria:
Thank you for your consideration and I hope that you are able to support our desires for the mentally ill in VA.