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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10/5/15  1:43 pm
Commenter: Scott Philbrook, EHS

the proposed regulations which states that LMHP, LMHP-Supervisees, or LMHP-resident must complete,

This subject is of great concern to me as a provider as the proposal requiring LMHP/LMHP-like staff is contrary to current trends in the mental health field and requires that additional staff must be hired at higher salaries which will hinder us providers to provide services because of budgeting concerns. This will have a direct impact on the consumer. The documentation turn around time will be longer thus creating a possible crisis for the consumer by heightening his/her psychiatric symptoms while awaiting documentation to provide services.Many of these consumers are already having to be put on a waiting list to receive services and community service boards are overwhelmed and understaffed. LMHP/LMHP-like staff are in short supply and these hours required to write ISPs which could be accomplished by lesser qualified staff do not count toward licensure supervision hours that are required to obtain LMHP status. 

CommentID: 42204