Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Amount, Duration, and Scope of Medical and Remedial Care and Services [12 VAC 30 ‑ 50]
Action Mental Health Skill-building Services
Stage Proposed
Comment Period Ended on 10/23/2015
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10/20/15  3:31 pm
Commenter: Stevie Phillips

Proposed Changes

The proposed changes to Mental Health Skills Building would drastically affect the clients and staff that we serve. Licensed and Licensed Eligible employees are currently taking care of all assessments and all re-authorizations for Mental Health Skills Building which is a difficult job. Adding the creation of ISP’s to their duties would not only be a disservice to the clients, but would make the job of Licensed and Licensed Eligible individuals even that more difficult. The clients are an important part of creating their ISP and feel the most comfortable discussing their goals with the clinician that is qualified and present in their lives. QMHP-A Clinicians are qualified to create and implement ISP’s and should be able to continue to do so, as they have successfully up to this point.

The proposed changes to Crisis Stabilization regarding authorizations that could take between 2-5 days to be approved is setting individuals with severe heightened symptoms up for failure. The goal and purpose of having Crisis Stabilization is to meet the client’s needs immediately and to avoid having the individual go into the hospital, jail, or worse- acting on potential suicidal or homicidal thoughts/plans. Having someone wait for an authorization to be approved is not only endangering that person or others, but it’s also going to lead to an increase in hospitalizations which takes “beds” from other individuals that could need that placement and increases the cost that Virginia is paying for Medicaid funded mental health services. The Creigh Deeds situation is a perfect but very sad example of what could occur if there are no beds available in a psychiatric hospital. By providing immediate crisis stabilization services to clients, we can attempt to avoid the hospitalization and save that bed for someone that may need a higher level of service.

Please consider not making the proposed changes. Please help us continue to be successful with our clients and allow us to provide sound therapeutic services without increased barriers.

Thank you,

Stevie N. Phillips, BS, QMHP-A

CommentID: 42244