Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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7/15/22  6:10 pm
Commenter: KJ Holbrook

Concerns RE Crisis Services

Mobile Crisis

I concur with the concern about prioritizing an administrative process over clinical response times. Engaging in the call center and data platform prior to initiating services seems to do just this. I understand that it may be come helpful to use the data platform to review the CEPP as part of treatment and the need to track these events, but to prohibit the initiation of services until these things are done is counterintuitive to the work.

The 8 hour billing limits is problematic in many ways. The long process of bed searches, wait times for medical clearance, and often complicated presentations lead to significant and ongoing engagement of staff well beyond 8 hours in a 72 hour window.


Community Stabilization

I support Peers being allowed to provide supports independently, along with QMHP-eligible staff. We have a large peer program and have found the one on one engagement most beneficial as it supports the mutuality tied to that service vs a ‘interdisciplinary team’ approach. And QMHP-eligible staff receive significant supervision and training as part of obtaining their hours as do LMHP’s in supervision or residency. The latter is able to provide these services so it’s not clear why the former don’t share in this ability.

Moving Comm Stab to a service auth from registration is another example of placing administrative process of clinical.

Requiring this only be provided in an individual vs group setting doesn’t allow for the benefits that can come with a group intervention. These services should definitely be individualized, but if a program can offer a group that educates on a particular coping skill, etc. and that interaction is made more beneficial by sharing with others- why would we not want to take advantage of the opportunity?


Residential Crisis Stabilization

I agree that 24/7 nursing is not always the level of staffing needed to meet the needs of individuals. Staff are trained in medication administration as well as first aide, which meet the vast majority of needs and the availability of on-call support should be considered, especially with the RN shortage in the state.

Adjusting the psychiatric eval to occur within 24 hours is helpful, but as individuals may have been referred to the CSU by psychiatric providers, allowing for a window to extend prior to the admission would reduce the repetitive assessments individuals may already be experiencing with their admission.

We understand that co-locating the CSU and 23 Hour service is the ideal best practice model, but there seems to be some language that would prohibit the ability to bill which is counterintuitive to the model the state has promoted. And the inability to bill a per diem service with any other behavioral health service impacts either the CSU or the supportive service that may be trying to be a bridge from physical discharge from the CSU to the community supports they need.

CommentID: 122541