This petition is especially concerning for me as well as the public behavioral healthcare system in Virginia, especially as regards some significant changes proposed in this petition. The first issue is that this petition includes private psychiatric hospitals as included in providing prescreening assessments.  This presents to me as a conflict of interest since prescreeners are making decisions that directly impact hospital admissions.  If private entities are allowed to perform prescreenings, this has the potential to significantly increase hospitalizations.  The public behavioral healthcare system is constantly working to reduce unnecessary inpatient admissions.

Furthermore, any prescreeners outside of the CSB system are not connected to the services provided through the public behavioral healthcare system and other community partners the way a CSB currently is.  This is part and parcel of the mission of the CSB system in Virginia.  The public behavioral healthcare system has access to multiple programs of services and various funding streams that provides direct care regardless of the individual's ability to pay.  This is not the case for the private sector. 

Public sector behavioral healthcare prescreeners at the CSBs are very sensitive to medical necessity criteria for involuntary hospitalization and often have to intervene now to prevent unneeded hospitalizations requested by private providers.  Furthermore, this petition, if approved, removes the ability of the public behavioral healthcare system to hire, screen, perform quality reviews, hold accountable, or discipline prescreening providers providing prescreenings outside of the CSBs. 

Overarching these concerns is that this petition, if approved, will designate the individual in the community as a private provider being "a designee of the Community Services Board that serves the area where the client is physically located during the time of assessment, or that provides outpatient treatment to the client with all powers granted under applicable law."  This essentially removes these private providers from under the direct authority of the CSB and sets them up a "a designee of the CSB" without any accountability to that CSB.  This is to me, unconscionable. 

Having worked with private providers within other services, and as a private provider myself, I would opine that there is little control over the quality of the services being provided and the outcomes of those services (outside of the marketplace).  This is not the case with the public behavioral healthcare system which labors under multiple administrative and reporting burdens that do not apply to the private sector.  I am diametrically opposed to the approval of the changes proposed in this petition.  They would not improve the prescreening system, but would further complicate and already complex process and system for the community and result in an increase in hospitalizations.

I would alternatively proposed that individuals in the private sector wishing to work with the CSBs in providing prescreening assessments could instead become involved in providing these services through temporary service agencies.  Alternatively, they along with the public behavioral healthcare system in the state could explore other contractual vehicles to expand the staffing capacity and ability of the CSB system to provide prescreening assessments.