Please see the comments below submitted on behalf of the Virginia Beach Department of Human Services (VB CBS) regarding proposed changes to Mental Health Case Management.

Face-to-Face and Community Contacts

The current requirement of one face-to-face contact per quarter is more manageable than the proposed two face-to-face contacts for case management services. This doubles the requirement and is unlikely to be well-received by some individuals and families served. We ask you to consider that many of them already find it difficult to meet once each quarter. Doubling this requirement may increase scheduling difficulties, but we recognize that this is not the case for every individual and family.

While we understand the benefits of seeing individuals across settings (and are in many instances doing so successfully), requiring one of the face-to-face events to be in the community does not seem to account for the individual’s right to choose and their needs. Many individuals and families are protective of their privacy and may prefer to meet only at the office. Additionally, many face transportation challenges. This could discourage some individuals and families in need from accessing services.

The adult population we serve is often seen in the community. Perhaps consideration could be given to allowing some face-to-face appointments in the office, such as before or after medication management visits, for example. This may help improve continuity of care.

Revisiting the availability of mental health skill-building services to ensure that case management requirements are not further stretched should be seriously considered. It appears that some of these requirements are being integrated into case management tasks. A cost analysis might also be beneficial.

Assessing CM Levels of Intensity

The descriptions of how we categorize service intensity for individuals are heavily focused on the adult population. High, medium, or low are very subjective guidelines and could be confusing for families moving between localities. We suggest that more consideration be given to the child and adolescent population. For instance, an individual deemed to have a low level of need might, in fact, have parents who struggle with system navigation and daily activities. In such cases, their needs could be categorized as high. Conversely, someone appearing to have a high level of need might have parents who are very experienced with navigating systems and require only minimal assistance.

Tiered CM could introduce additional barriers for CSBs serving the BH population, as they don’t consistently maintain the same level of acuity during service. LOC is already monitored regularly and appropriately. It would be burdensome to constantly reassess the level if the billing structure does not support funding for frequent assessments and other related activities/requirements. An assessment that accurately determines the level of need, service frequency, and caseload size is essential. What flexibility, if any, will be permitted for sudden changes in caseload intensity?

Tracking Time Spent Based on Intensity

Requiring CSBs to track and report the average service time per individual each month is burdensome and subjective. How does providing a minimum of two hours per individual relate to their service intensity? If only 1.75 hours are provided but all other billing requirements are met (face-to-face contacts, collateral contacts, etc.), will CSBs be unable to bill? Also, the current reporting structure should be reviewed and updated to ensure accurate tracking.