Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Previous Comment     Next Comment     Back to List of Comments
6/20/22  2:20 pm
Commenter: Anonymous

Appendix G; Community stabilization
  1. Changing the current registration process to a service authorization will likely pose an issue in terms of individuals quickly accessing care. Currently the regulations do no state how long MCO's have to make a determination which will leave providers in limbo in terms of their ability to quickly provide services. Also there is inconsistency among the MCO's in terms of medical necessity criteria and the amount of units they allow for different programs. This is a recurrent issue that has not been solved, so adding community stabilization to this will only heighten the issues. Also there is a clear shortage of licensed and licensed type staff in community mental health; however we are required to employ them and pay them for their expertise; but when they determine medical necessity criteria, the MCO's can dispute this and this undermines their clinical judgement and perceived value adding to burn out and departure from community mental health.
  2. Providers across Virginia are struggling to retain qualified staff in order to provide the new BRAVO services in addition to the original services. Changes are expected; however drastic changes such as this in addition to the additional administrative burdens attached with Project Bravo and the database are concerning and may result in less Virginians being able to access quality care. 
CommentID: 122147