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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10/23/15  9:04 pm
Commenter: Rescare/Creative Family Solutions

Concerns Pertaining to Proposed Changes

Proposed regulation for Mental Health Skill-Building ISP development: (Pg 19 I #3):  the "LMHP, LMHP- supervisee, or LMHP- resident shall complete, sign and date an ISP within 30 days of the admission to this service"

This proposed regulation appears to undermine the credibility of the direct service providers whom actually provide the MHS service to clientele.  In implementing these services, the direct service provider rather than the LPC ultimately tends to have a greater insight to the individual’s pertinent needs and preferences. Furthermore, given that there is a distinct shortage of LMHPs in the state, it is seemingly ineffective to attempt to place an increased work load on those we currently do have. A greater impact could be made by taking into account the overt significance of the “working knowledge” that many if not most direct service providers have.


Proposed Regulation for Mental Health Skill-Building proposed ISP hours per week (pg 19 I #3): "The ISP shall include documentation of how many days per week and how many hours per week are required to carry out the goals in the ISP.  The total time billed for the week shall not exceed the frequency established in the individual's ISP."

This regulation fails to take into consideration the innate nature of SMI—that it cannot be predicted or quantified on a consistent basis.  It is short-sighted, as it does not account for the crises that regularly occur and can result in expensive, time and resource-consuming psychiatric hospitalizations.  Should MHS services be rigidly limited by an ISP, this could, and likely would, increase overall expenses by decreasing preventative measures. Regulations of this nature would limit recipients to a rote, generalized service regimen, with little consideration for the specific need of the individual—rendering the term “ISP” to be incongruous and somewhat satiric.

CommentID: 42336