Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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8/18/23  10:07 am
Commenter: Jen DuVon, Brain Injury Connections of the Shenandoah Valley

Emergency Assistance Requirement a Burden on BI CM providers

"Guarantee that individuals have access to emergency services assistance either directly or on-call 24 hours per day, seven days per week and holidays on a 24-hour basis. This may be done via telephone and face-to face contact a phone answering service and/or coordination with other MCOs providers and DBHDS administered crisis services."

Could you provide clarification on this? Brain injury service providers are not trained mental health providers, nor are we crisis response clinicians. Placing this burden on BI case management providers is first and foremost outside the scope of the services we are trained to provide. Contracting for this service is also very expensive and places additional burden on state agencies. There are already established 24/7 mental health emergency service providers in our communities. Can this requirement be interpreted to mean that we will ensure clients have access to/information needed to contact emergency/crisis service providers? If contracting is required, is this sufficient to meet the need or does this imply that having a staff person on call will be required? If so, this requirement will be significantly burdensome on all state BI service providers. 

CommentID: 219315