Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
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6/12/22  6:23 am
Commenter: Willard Vaughn

The Final Word...
 

I want to begin by saying thanks to the few of you that read and commented on my petition.  

As someone who has been a preadmission screener for the better part of twenty years and now owning my own practice, with this new opportunity arising from the integration of private providers into the public system, I wanted to be able to provide the complete spectrum of services to my clients. 

To clarify for some that misunderstood, this rule change would only apply to agencies (providers) that are fully licensed by DBHDS...just like CSBs have to be fully licensed by DBHDS.  Licensed providers have oversight and are fully within the authority granted to DBHDS by VA Code.  At present, those that are Certified Preadmission Screening Clinicians can take that certification and perform this task anywhere in the state.  My proposal makes that impossible, and gives ownership (as well as warranties) to the individual's employer. If an agency employs experienced people as I have suggested that properly train and prepare their clinicians, this could be an innovative way to solve the current workforce shortage and raise the standard of care for everyone.  

With that said, I will concede to one point that a couple of you made regarding hospitals.  One of the things that work in our mental health system is that there is always an objective third party to evaluate a person in crisis and make a decision.  When assessors employed by a hospital have the ability to insist that a client stay at their hospital, that does seem to create a conflict.    

Another of you made reference to ownership of documentation, and there is a simple solution to that...use one system that all licensed entities are forced to use.  Other states do it quite successfully.  But that is an entirely different rant.  

To be frank, CSBs have insisted on a monopoly over a multitude of services for the past 56 years with crisis services being one of the few strongholds.  This makes many of your comments not surprising because more than anything else, monopolies fear competition in a free market that can provide a better quality of service and bring innovative ideas to the table.  Competition also forces a monopoly to be accountable for the failings of the system which is not something that any public system excels at.  All jabs aside, I am sincerely afraid that the Marcus Alert system will go from the most progressive and innovative thing that this state has seen in many years, to what is simply a more complex elaboration on business as usual in Virginia's mental health system with an easier to remember phone number.  As a trench worker turned business owner, I think there is a place in all of this for me and those like me:  providers who are truly client focused that want to provide quality and compassionate care to anyone that needs it.  I would hate to see a public system turn us away out of fear of creating something great.  

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