MH requirements are greatly above that for ARTS programs, allow little flexibility, and concerned will deter many from implementing these much needed services. Despite more requirements, rate is considerably less than ARTS. Suggest re-aligning closer to ARTS format. Recommend not passing this appendix without more review and input. What many understood as intended to be an alignment with ARTS IOP and PH, seems to be more of a creation of stand-alone program/clinic, versus a new ability to offer a similar group service structure for MH. With the numerous competing demands, changes and current requests, suspect many agencies have not had time to review thoroughly and give input.  

A few key point examples from the MH IOP draft regs:

• Staffing requirements include Full time Clinical Director – Not in ARTS
• Staffing requirements include Physician/NP/PA for weekly med management- Not in ARTS
• Staffing ratio 1:5 clients- Not in ARTS
• Supervisor ratio 1:6 staff  - Not in ARTS
• Accreditation by CARF or Joint Commission (not required in ARTS, have heard may have 2 years to get this) There is no other specific MH service menu item that requires this in Virginia that I am aware of.
• Three groups and 2 individual sessions per week- Individual sessions are available in ARTS as a separate service but not required/prescribed, recommend allowing for more individualized . treatment. This will create a 5 day a week program if need 3 groups (3 hours each), 2 individual sessions, and1 x weekly med management, equivalent with more of a partial hospitalization level of care. 

Reminder of rate differences:

ARTS IOP rate: $250 group

MH IOP rate: $141.50 per diem

ARTS PH: $500 group

MH PH: $120.58 ($220 if in a hospital) per diem