Dear Ms. McClellan:

The Pyramid Healthcare, Inc. (“Pyramid Healthcare”) family of companies is providing information and feedback below regarding the Virginia Department of Medical Assistance Services’ (“DMAS’”) Draft Addiction & Recovery Treatment Services (ARTS) Provider Manual (Chapter II), Provider Participation Requirements (see here). We urge you to incorporate our feedback regarding additional requested clarification regarding the Draft Manual’s proposed specific provider requirements—specifically with regard to remote virtual training.

As background, the Pyramid Healthcare family of companies is an integrated behavioral healthcare system. Founded in 1999, Pyramid Healthcare serves thousands of clients per month throughout over 80 residential and outpatient locations across seven states. We offer a comprehensive behavioral healthcare treatment continuum including: substance use disorder, mental health, autism, and eating disorder treatment. For over 20 years, we have been committed to our mission of improving lives through administering personalized treatment to provide help, healing, and hope to adults, children, adolescents, and their families.

In Virginia, Pyramid Healthcare began operations in July 2021 when we opened our Pyramid Healthcare detox and residential treatment center in Newport News. We expect to ultimately provide nearly 150 beds for detox/residential substance use disorder and crisis needs at this facility. We also recently opened our outpatient treatment facility onsite in Newport News for adults with substance use and co-occurring disorders. We offer intensive outpatient services (IOP), outpatient services (OP), and certified peer recovery support services in addition to case management support and family therapy. We are in the process of expanding our footprint in Virginia through our New River Valley Residential Treatment Center in Radford, which is currently under renovation and expected to begin operations in 2023. The facility will initially provide outpatient partial hospitalization programs (PHP) and low-intensity residential services (LIR), although we hope to eventually provide a more complete continuum of care over the coming months.

We thank DMAS for your efforts and for the proposed changes. We would, however, request clarification regarding the Draft Manual’s proposed changes to specific provider requirements (page 21 et seq.) specifically with regard to ASAM trainings to be completed by staff. We recognize and understand that ASAM training will undoubtedly be required to properly align training on services and regulatory requirements. We request DMAS to clarify whether these trainings must be rendered physically in-person or whether remote virtual training through entities such as The Changes Companies would be acceptable. Furthermore, we urge DMAS to adopt remote virtual trainings as a viable option to complete this regulatory requirement. Remote virtual trainings are a widely-adopted and accepted solution that aligns with best practices while recognizing the reality of modern workforce challenges. We request the Draft Manual be amended to clarify that remote virtual trainings would meet the requirement.

Please consider this feedback and make appropriate revisions to the clinical policy in order to ensure a robust network of providers across the full continuum of care for Medicaid substance use treatment and recovery services. Thank you for your support of mental health, behavioral health, and substance use providers in Virginia and for considering my requests on behalf of Pyramid Healthcare. If we can provide any additional information or materials, please contact me at crosier@pyramidhc.com or 667-270-1582. In addition, we invite you or a representative of the Department to reach out and schedule a visit to our Newport News location sometime soon to learn more about our programs and services.

Sincerely,

Collan B. Rosier

Vice President of Government Relations

While training for people who supervise Peer Recovery Specialists is certainly helpful, to add the requirement in this manual, that the very specific "DBHDS Peer Recovery Specialist Training" must be taken, will create additional barriers for peer support service delivery. 

I have not been able, as of a search today, to find where this specific training is being offered. Without it being offered continuously and remotely,  it will delay being able to provide peer services, and/or, put valuable RCSUs for example, immediately out of compliance when enacted. It also does not allow for time for onboard new supervisors and getting them trained when there is staff turnover. 

It seems outside the scope of this manual to require a very specific training, for the supervisors of those directly delivering services. Many programs have long time embedded peers and supervisors that are doing an excellent job and this adds to regulatory burden, especially if not immediately and easily available.

In addition, it is suggested that Peer Recovery Services regulations should be reviewed to make the delivery of Peer Recovery Services easier across the board. If a person is a Certified and Registered Peer Recovery Specialist, they could most simply, be qualified to  deliver group or individual peer services, the same as an LMHP can deliver individual and group counseling.

Certified Prescreeners have undergone education and training necessary to perform prescreening duties that should be independently billable. If not independently billable, recommend allowing indirect supervision of activities, meaning via the review and signing off on the prescreening by an LMHP.   

Providers have been told they can use 2 LMHPS and bill at the Team 5 level for mobile crisis, including during webinars.  The current manual also notes being able to use the HT modifier when using 2 LMHPS. Please make this clear by adding the 2 LMHPs to the Team Composition Table.