Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Previous Comment     Next Comment     Back to List of Comments
8/15/23  11:39 am
Commenter: Lisa McCarthy, Brain Injury Services

Provider Requirements

The draft states:

"Guarantee that individuals have access to emergency services assistance either directly or on-call 24 hours per day, seven days per week and holidays on a 24-hour basis. This may be done via telephone and face-to face contact a phone answering service and/or coordination with other MCOs providers and DBHDS administered crisis services"

Could there be clarification on what is meant by “emergency assistance” and how that differs from the previous version that stated “emergency services”.  Current providers of brain injury case management do not and have never provided emergency assistance but do develop safety plans and direct clients to the use of 911 and 988 as needed.  Requiring programs to provide 24/7 access would be a significant financial burden by adding costs for on call pay and will certainly lead to increased turnover and challenges with recruitment and staff retention which are already a significant issue for existing programs.  As private non-profits we can not compete with the salaries of state agencies and CSB’s and attract staff because of the work life balance we promote.  If staff are willing to work jobs where they will be on call then they will certainly choose to work at larger state agencies who can afford higher salaries.  Brain injury case management services have been provided  services to the community for decades without 24/7 coverage and we have seen no evidence that it’s a needed addition.

CommentID: 218705