I ask that whoever reads these comments will take into consideration that these are the voices speaking up for our clients and many other providers in the State of Virginia that may not have been unaware of the townhall comment period.

I am a very concerned licensed professional who has been in the field for 12 plus years.  I have been very familiar with regulation changes over the years and it appears that Mental Health Skill-Building Services and other Community Mental Health Rehabilitative Services are constantly being looked at.  I understand we need regulations and that we need to follow them; however, I think enough is enough!  Our system is broken and this directly affects the clients we work with every day.  The system is broken in that all providers are NOT held to the same standard.  Larger companies receive approximately one audit a year from DMAS, Licensing, etc. and smaller companies do not receive any.  I know of companies that have not received one audit since they have been in business.  I ask that instead of scrutinizing these services that the same standard for all providers be put in place.  This will ensure quality care is being given to clients across the board and weed out providers that are not providing the quality services.  Enforce regulations that are already in place!

As for the current proposed regulations:

I am in support of allowing the higher level of care Non-Residential Crisis Stabilization in the consideration of Mental Health Skill-Building criteria.  I believe Non-Residential and Residential Crisis Stabilization Services are providing the same services except in different settings.

I am in support of the deletion of the change in unit structure that was previously in the proposed regulations.  Providers would end up losing a significant amount of money if this ever goes through. 

I am not in support of LMHP and or LMHP types completing, signing and dating the ISPs only.  This creates a problem in that it is very difficult to find Licensed and/or Licensed professionals individuals to fill these positions especially in rural areas.  Furthermore, it is more costly for businesses as these positions will require a higher salary.  As a Licensed Professional I would rather work directly with clients instead of being in a situation where I am required to do more paperwork.  We already complete intakes, reviews, etc. of client services in MHSS. 

I am not in support of requiring authorization for Crisis Intervention and Crisis Stabilization Services.  I have worked in Crisis Services in the past and getting the clients help quickly is crucial!  Many clients are dealing with thoughts of harm to themselves and/or others and need crisis services immediately to avoid hospitalization.  Authorizations can take up to 5 days in some cases.  Even if the turnaround for authorization approvals were 24 hours that could potentially leave the client without services and potentially hospitalized.

Thank you for taking the time in reading my comments!