The Virginia Association of Community-Based Providers (VACBP) represents private-sector providers of behavioral health, substance use disorder and ABA services throughout the Commonwealth of Virginia, and submits these comments on behalf of our members.

Page 35, Community Stabilization – Shift from registration to service authorization

Proposed changes:

“Providers shall submit service authorization requests within one business day of admission for initial service authorization requests. If submitted after the required time frame, the begin date of authorization will be based on the date of receipt.

Service authorization requests must include, at a minimum:

1. A complete service authorization request form. The service authorization form must be submitted with the required DBHDS crisis data platform reference number.

2. Documented referral from discharging provider, if applicable. The referral must include the name of both the referring provider and the community stabilization provider.

Service units are authorized based on medical necessity with a unit equaling fifteen minutes.”

Concerns: There is significant concern that slow MCO response times will delay service delivery, particularly over holidays and weekends. While the intent of community-based crisis services is to meet the needs of individuals in crisis and reduce costly hospital stays and emergency room visits, this proposed change will add hurdles and barriers to the delivery of services in the community and limit the ability to meet these goals.

Recommendations:

• Provide for an automatic authorization for a specific number of units to support assessment and initial planning activities within the first 24 hours, to span two calendar days, as appropriate. This initial service funding should not be subject to a prior authorization process.
• Require that the Medicaid MCOs prioritize these reviews and responses with a turn-around time of one calendar day to avoid service disruptions and/or compromise quality care.
• Evaluate the extent to which increased utilization of community-based crisis services is reducing hospitalization and ER visits. While we understand that utilization of the Community Stabilization service is higher than anticipated, it provides a much better and more affordable option to hospitalization.
• Evaluate the extent to which increased utilization is tied to fraud and increase efforts to go after the providers that are not appropriately delivering the service.
• Consider whether the assumptions used to budget for utilization of these services is adequately considering the significant increase in the need for behavioral health supports, particularly crisis services, in communities across Virginia.
• Consider the extent to which the lack of a seamless continuum of community-based behavioral health services is impacting the utilization of crisis services. With this, the VACBP will continue to advocate in support of the rate study that will provide the critical information needed to proceed in the implementation of Project BRAVO.