Agencies | Governor
Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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4/30/21  7:19 am
Commenter: Natalie Handy



  1. Pgs. 4-5, 7 of Appendix E; MH-IOP Level of Care Guidelines; Service Definition: “…A MH-IOP requires psychiatric oversight with at least weekly medication management included in the coordinated structure of the treatment program schedule.”


Public Comment: Please consider revising this service requirement to allow for psychiatric providers to schedule medication management appointments as medically necessary, but at minimum on a monthly basis. Additionally, individuals commonly express a preference to use their primary care physician instead of a psychiatric provider, or the individual declines a referral for a psychiatric evaluation and medication management. In these scenarios, please consider allowing individuals to continue participation in MH-IOP. Providers should document the individual’s choice and preferences and also engage in service coordination with any outside prescriber.


  1. Pg. 8 of Appendix E; MH-IOP Level of Care Guidelines; Service Limitations: “MH-IOP may not be authorized or billed concurrently with…Mental Health Skill-building …”


Public Comment: Many individuals admitted to Mental Health Skill-building services would benefit from participation in a MH-IOP program. However, discontinuing the intervention and support provided through MHSS services would likely cause regression in the individual’s treatment progress. MHSS extends hands-on, practical, and real-time skill-training for individuals in their home and community setting, which is outside of the MH-IOP service scope. Please consider allowing concurrent service authorizations for MH-IOP and MHSS.


  1. Pg. 8 of Appendix E; MH-IOP Level of Care Guidelines; Service Limitations: “MH-IOP may not be authorized or billed concurrently with…Therapeutic Day Treatment…”

Pg. 9 of Appendix #; MH-IOP Provider Participation Requirements: “Regardless of setting, these programs should not be disruptive of the school day or provides as part of the school day structure for youth participants.”


Public Comment: Limiting concurrent MH-IOP and Therapeutic Day Treatment service authorizations will result in youth who lack the support and intervention needed to function well during the school day and could result in more restrictive service interventions or school placements as a result. MH-IOP aims to significantly increase the youth’s healthy ability to cope, relate interpersonally, and problem-solve. MH-IOP providers who coordinate services with TDT providers are more likely to see these skills generalized across service settings with the goal to successfully discharge from both programs.  Otherwise, the service limit will likely result in youth and guardians who decline MH-IOP in an effort to preserve TDT services, forfeiting MH-IOP a needed and beneficial service opportunity.

CommentID: 97763