Caliber Virginia appreciates the opportunity to provide feedback on the proposed updates to Mental Health Case Management (MHCM) as part of the Commonwealth’s Right Help, Right Now behavioral health redesign initiative.

We support efforts to improve coordination of care and enhance system efficiency. However, we have significant concerns regarding the proposed structure of MHCM and its potential impact on service delivery, workforce stability, and access to care across the Commonwealth.

First, the revised definition of case management shifts the service further away from direct intervention and reinforces its role as a coordination-based model. While care coordination is an important component of the behavioral health system, many individuals currently rely on case management services that include elements of hands-on support, engagement, and problem-solving. Limiting the service to coordination functions may create gaps in care, particularly for individuals who require more direct assistance navigating systems and maintaining stability.

Second, the proposed engagement and contact requirements may reduce service intensity. The minimum requirements for contact, including limited face-to-face interactions over extended periods, may not be sufficient for individuals with higher levels of need. Many individuals served through case management require frequent engagement to remain connected to services and avoid deterioration. Reduced contact expectations may increase the risk of disengagement and ultimately lead to greater utilization of crisis and inpatient services.

Third, the transition to a flat caseload cap model presents operational concerns. While the cap of 45 individuals per full-time case manager provides standardization, it does not account for differences in acuity among individuals served. A uniform caseload limit may inadvertently reduce flexibility for providers to appropriately distribute workload based on complexity and need.

Additionally, the updated requirements introduce increased documentation expectations, including detailed assessments, individualized service plans, quarterly reviews, and ongoing monitoring and documentation of all service-related contacts. While these requirements support accountability, they also increase administrative burden and may reduce the time case managers are able to spend in direct engagement with individuals.

We also have concerns regarding the potential impact on underserved and minority communities. Individuals in these communities often face additional barriers to accessing care, including transportation, employment constraints, and limited support systems. A model that relies heavily on coordination rather than direct engagement may not adequately meet the needs of these populations and may unintentionally contribute to reduced access and poorer outcomes.

Finally, we note that limiting case management providers to specific entities, such as Community Services Boards, may restrict provider participation and reduce access to care in certain regions. Expanding provider eligibility or allowing for greater collaboration with community-based providers may help ensure broader access and continuity of care.

Recommendations:

Caliber Virginia respectfully recommends the following:

• Maintain flexibility within the case management model to allow for direct engagement activities when clinically appropriate
• Consider a tiered or acuity-based caseload model rather than a flat cap to better reflect individual needs
• Increase minimum contact expectations for individuals with higher levels of need
• Align reimbursement with administrative and documentation requirements to support provider sustainability
• Expand or clarify provider eligibility to ensure adequate access to services across all regions
• Incorporate safeguards to ensure underserved and minority populations continue to receive appropriate levels of support

Caliber Virginia remains committed to working collaboratively with DMAS to ensure that the redesign of Mental Health Case Management strengthens coordination while preserving access, engagement, and outcomes for individuals across the Commonwealth.