COMMENTS: MHSS Regulations

Dear Ms. McClellan:

Thank you for the opportunity to comment on the proposed regulation related to Mental Health Skill Building (MHSS) [120VAC30-50]. As a provider of mental health skill building services, we currently support 118 individuals throughout Virginia. We believe these changes, which build upon many of the changes in the previous emergency regulations, will improve the quality of care for many individuals, but we do have some concerns noted below.

The proposed regulation overview indicates that this regulation will not have an adverse impact on any particular locality. We believe these new regulations disproportionately affect rural communities where a full service continuum often does not exist. MHSS serves an important role in rural areas where there are many services gaps. We are concerned the changes in eligibility will have adverse impact in rural areas where consumers who are seeking care have few options. We are hopeful that DMAS, in coordination with the Department of Behavioral Health and Developmental Services (DBHDS) will continue to examine the continuum of care in all communities to ensure services are developed over time that will meet these critical gaps in care.

The other concern we note is with the six month service-specific provider reassessment. Many of the individuals that receive MHSS see little change in their long-term diagnosis. Consequently, despite the ongoing training and support provided through MHSS, changes frequently take longer than six months to manifest. We recommend a 12 month service-specific provider reassessment. This timeframe more accurately reflects the time needed to work with consumers to gain self-sufficiency and other skills needed to live and work independently in their communities.

We are appreciative of DMAS’ efforts to work closely with providers in the development of these regulations. We are hopeful this collaboration will continue in the future, particularly as we examine the long-term impact of this regulation for individuals in rural or underserved areas. Should you have any questions, please contact Rick Mitchell, Chief Clinical Officer, at RMitchell@fpscorp.com or 276-971-1488.

Thank you,

Jon Morris

Chief Executive Officer

Family Preservation Services of Virginia