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, Length of Service for Community Stabilization

Concern: The length of service for Community Stabilization previously allowed seven days with the option to reauthorize for up to 14 days if the client was still actively in crisis. This timeframe was removed, making it unclear how long the provider can deliver the service.

Recommendation: Clearly define the length of service to avoid confusion between providers, MCOs and clients. Having a defined minimum length of stay based on the service definition and DMAS expectations would be helpful.