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
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10/23/15  4:17 pm
Commenter: Jessica Dent

Proposed changes

I would like to express some concern in response to these proposed changes. First, the suggestion that service plans should be created by licensed staff seems counterintuitive. This makes little sense as the licensed staff members have minimal contact with clients. Usually these staff members are used for the purposes of assessing clients, which is a snapshot of their current symptoms and progress they have made. However, qualified mental health professionals (QMHP) who do not have licenses are usually the staff who spend the most time with these clients and are able to explore and focus on their needs and goals. This is also helpful as it allows greater opportunity for the clients to play and active role in the development of their service. Additionally, it allows for the service plans to be amended as needed, as opposed to only once per quarter after setting up and appointment. Moreover, licensed staff members are often scarce and those working toward licensure are not able to apply these hours toward licensure, making them unlikely candidates for this type of work. This would also impact the financial feasibility of services as licensed and license-eligible staff members require increased payment, placing greater strain on companies already working to be competitive. I urge you to re-consider such steps may prove detrimental to the clients who are in need of these community-based services. I also have concerns regarding the identified number of days and hours per week indicated on the service plan. While indicating a suggested number of hours and days seems reasonable, it is concerning to me that clients would be constrained to this limitation. My concern lays with the severity of the mental illness and maladaptive behaviors that community mental health worker provider services to. I understand that most weeks, clients may need only a few days, but other weeks they may be facing homelessness, increased symptoms, and a myriad of other stressors that require temporary increase in services in order to maintain safely in the community. As community mental health provider, my primary concern is that the individuals I work with are able to safely remain in the community and have their needs met. With overly strict limitations, these clients risk not having access to increased services when needed. This leads to may last concern, regarding community-based crisis intervention services. I the past this service was available immediately upon application. New proposed regulations would require authorization for crisis services in the community. My concern is that this authorization process could take several days. Unfortunately the nature of a crisis is often very time-sensitive, if forced to wait several days in order to provide this service, we may miss the window of opportunity to keep these clients out of the hospital. As a mental health professional, I would prefer to treat these clients in the community as it is much less disruptive to their lives, allows for greater opportunity to address stressors and triggers in the real-world setting. Additionally, providing crisis services in the community would save the state a significant amount of money as a few days of community-based crisis services is dramatically less expensive than a few days in the hospital. Please do not place the health and safety of the clients we serve in the community at risk by passing these potentially dangerous regulations. Thank youfor your time and consideration.

CommentID: 42330