I strongly urge that mental health services in Virginia  be beneficial to those who suffer from mental illness.  I feel like we have digressed in the appropriate treatment for individuals with mental illness due to drastic cuts with stricter eligibility criteria and decreased access to services.

 Working daily with those who suffer from mental illness allows a person a firsthand account of the daily struggles they face and a better understanding of how limited access to services is detrimental for their daily functioning.  Each week we receive calls from members of the community looking for intensive mental health services and we must turn them away due to ineligibility.  We are only able to refer them for outpatient counseling (provided twice a month) or for psychiatry services (fifteen minutes, once every three months) if they can get into a psychiatrist at all.  Most of these same community members do not meet the criteria for the CSB either.  It is heartbreaking to me that individuals who are reaching out and trying to find the help they need are turned away with no real support options available to them.  

I have heard numerous times about the direction of mental health care being urged to follow medical models, yet Virginia's mental health care does not support programs that are preventative in nature.  In the medical field a lot of time, money and effort are focused on preventative care options due to cost factors that are incurred with serious medical conditions.  I have discussed this very matter with representatives from DMAS and the Secretary of Health in Virginia.  Programs like mental health skill-building, crisis stabilization and other intensive community based programs DO help PREVENT increased costs of serious mental health episodes that require inpatient psychiatric care and/or incarceration (which is where many individuals find themselves because they have no access to mental health care).

I also strongly support the VACBP's comments and concerns about the proposed changes.

Concerning the proposed regulations which states that LMHP, LMHP- Supervisee, or LMHP- resident may complete, sign and date an ISP:

• In order for providers to have an LMHP/LMHP-like staff member to complete ISP’s, they need to hire staff.
  • In many parts of the state, there is a severe shortage of licensed or licensed eligible individuals to fill these positions which will mean that MHSS providers will not be able to fill the positions or stay in business.  Those licensed or licensed eligible who are available are not apt to take jobs such as these because they are paperwork intensive and they want to work with people, not just fill out papers.
  • These individuals are in high demand and will require higher salaries than the individuals who currently complete this level of paperwork which will be a financial hardship on businesses providing MHSS.
  • The work that would be required of these positions does not meet the requirement for hours toward licensure and as such do not make these jobs attractive to licensed eligible individuals, making it even more difficult to find staff to fill these roles.
• This approach to writing the ISP’s seems contrary to current trends.
  • The definition, scope of service and intent of MHSS has been modified to the point that regulatory bodies state that a QMHPP can provide the service, implying that the service is less intensive than others, yet it now requires and LMHP to write the ISP. 
  • These ISP’s will be written by staff who have very little contact with the client.

Concerning the proposed regulation requiring an authorization for Crisis Stabilization:

• Currently, the timeframe on receiving an approval for other services is anywhere from 2-5 days.  Considering that a client is in a crisis situation when they come into this service, it does not seem feasible to wait for an authorization to be approved to begin services.  An authorization requires a large amount of paperwork and this would further delay the beginning of actual services.
• If the intention is for providers to begin services without the approval, are providers guaranteed payment if the authorization is eventually denied?
• Delays in the beginning of the provision of these services could lead to clients seeking more expensive and intrusive higher levels of care.

Concerning the proposed regulation concerning the number of days per week and hours per week are required to carry out the goals in the ISP:

·         Will providers be paid if they provide services outside of these prescribed levels set forth in the ISP?  Client’s needs fluctuate greatly over the course of time and have issues that arise that may require additional hours/days of services.  Will these either be denied or reclaimed on audit?  This does not seem that it lends itself to meeting the client’s needs or a person-centered approach.

Concerning the deletion of the change in the unit structure that was formerly mentioned in the proposed regulations:

·         While the language in the Economic Impact Statement states that the proposed changes to rate structure were budget neutral, provider’s estimate a loss of 10-25% of revenue would be lost due to the change.  This would seriously impact providers ability to continue to provide services as well as have the quality assurance and supervisory measures in place to make sure the services that are provided are of high quality.

·         We wholeheartedly support the deletion of the language that may have led to these reductions.

Concerning the regulation change in which Non-Residential Crisis Stabilization may be used as a higher level of care in the consideration of MHSS eligibility criteria:

• We support the addition of this service as a higher level of care, as the services provided in non-residential are the same as in residential CSS, they are just provided in a different setting.