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 36 – Obtaining information from MCOs/Consecutive Authorizations/Registrations
Proposed language:
“The referring provider must determine what other services the individual is receiving prior to referring to Community Stabilization. It is the responsibility of both the referring provider and the Community Stabilization provider to determine if the individual has another community behavioral health provider and should contact the MCO/FFS contractor, caregivers and natural supports prior to initiating Community Stabilization services.”
Concern: Providers are already experiencing significant challenges with receiving information from the MCOs regarding if an individual is receiving other services. In some cases, the MCOs aren’t responding in a timely manner. In addition, some MCOs are citing HIPPA compliance concerns as a reason not to share patient information with providers or are requiring a provider to have the member on the phone to approve sharing their information which is not always possible or practical in crisis situations.
This is a particular challenge in the context of consecutive registrations/authorizations. If a provider is not able to promptly receive information from an MCO about open or recent registrations/authorizations, they are not aware of whether an individual is eligible to receive service. In some cases, providers deliver the service, only to learn when the MCO responds or a claim is declined that the individual had received other services that preclude payment for the services provided. A lack of clarity regarding how “consecutive” is defined has also raised as a concern.
Recommendations: