On behalf of SpringHealth Behavioral Health and Integrated Care, I write to recommend allowing associate level clinicians to provider services under 12VAC30-122-550 Therapeutic Consultation.

At SpringHealth we specialize in providing professional behavioral and intervention services for youth and adults diagnosed with Intellectual and Developmental Disabilities (IDD), Autism Spectrum Disorder (ASD), and mental illness. One of our greatest challenges to ensuring those that require services and supports receive them is recruiting licensed clinicians to provide services to adults with IDD, even more so in rural parts of the state.  One way to address our workforce challenge and to ensure access for clients in rural areas of Virginia would be to allow associate level clinicians to provider services under Therapeutic Consultation.   

Allowing associate level clinicians such as LMHP-RP, LMHP-S, LMHP-R, as well those seeking their BCBA / BCaBA, to provide services under Therapeutic Consultation would also be consistent with Community Mental Health Services under the Medicaid State Plan such as behavior therapy, mental health skill building, and intensive in-home supports, to name a few.  This would assist with addressing workforce challenges and shortages and afford level clinicians the opportunity to gain experience working with adults. 

Additionally, I would concur with the other comments submitted regarding billing in 15-minute units for Therapeutic Consultation, as this change would standardize billing for providers who offer and bill for multiple services. 

I appreciate your consideration of my comments. 

Sincerely,

Michelle L. Willingham MS MHA BCBA LBA - V

State Director Virginia

For reference, below are the associated administrative codes: 

18VAC115-60-10

18VAC115-20-10

18VAC125-20-10

18VAC140-20-10