Agencies | Governor
Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
Amount, Duration, and Scope of Medical and Remedial Care and Services [12 VAC 30 ‑ 50]
Action 2011 Mental Health Services Program Changes for Appropriate Utilization & Provider Qualifications
Stage Final
Comment Period Ends 1/29/2015
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1/29/15  10:44 am
Commenter: Jacob Rheaume MSW supervisee in social work. River City Comprehensive Couns

Proposed changes to IIH regulations

As a provider of community mental health services I have concerns about proposed regulation changes pertaining to Intensive In-Home Services for several reasons.  First, shifting “care coordination”  from I.I.H. providers to local community service boards will likely result in overburdening an already strained agency. It is unlikely that the local CSB will be able to meet this increased demand for case management services should these proposed amendments be approved. 

Second, many of the clients receiving IIH services come from families with limited financial resources, and chaotic home environments, which further impedes their ability to schedule and maintain much needed ongoing case management appointments in an outpatient setting. In considering these changes one must ask whether or not the family has reliable transportation, flexibility with work schedules, and day care for other children, that will allow them to maintain case management services in a remote location. 

 IIH providers generally have more flexibility with regard to their scheduling and are better able to accommodate changing family schedules in a way that community services boards cannot.  The added strain on the local community service board created by the increase in consumers, coupled with the barrier to families created by requiring case management services to be delivered through the CSB rather than the agency delivering IIH services, will result in a gap in services. Briefly stated, clients will not be able to consistently maintain scheduled appointments.

Third, IIH providers have an ongoing relationship with the client as well as an intimate understanding of the family dynamic and are therefore better situated to assess and provide the case management needs of the clients they serve.  

CommentID: 37831