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 Mental Health Skill-building Services
Stage Proposed
Comment Period Ended on 10/23/2015
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9/23/15  12:26 pm
Commenter: L. Michelle Fisher

Allowing QMHPs to Write ISPs

This creates an unrealistic expectation, particularly in the more rural areas of Virginia where LMHPs are continually in high-demand for a variety of positions. Requiring LMHPs to create all ISPs and QRs for clients remove LMHPs from the clinical work they have trained for and been extensively educated about and transitioning them to a paperwork laden position. This change will require numerous agencies to complete restructure programs and create additional positions to accomodate this change while simultaneously reducing the clinical work provided aas the paperwork burden increases. Finally, this creates an increasedly likelihood of unethical behaviors in order to meet and maintain minimum standards with this new regulation.

CommentID: 42177