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
Previous Comment     Next Comment     Back to List of Comments
10/5/15  2:00 pm
Commenter: Scott Philbrook, EHS

required authorization for Crisis Stabilization services

The proposed regulation for requiring authorization for Crisis Stabilization Services seems counterproductive for the consumer in many ways. The time-frame for those in Crisis is paramount. Any regulations that delay the process of a consumer receiving crisis services in a timely manner puts that consumer in an unnecessary at-risk situation. In the advent of delay the consumer may be forced to have to access higly expensive and often unwarranted intrusive higher levels of care thus creating apprehension for the consumer to seek such care and could put his/her life in jeopardy or someone else's. As we have seen in far too many tragedies in the news media consumers need speedy and less cost preventive intervention. In addition, I wholeheartedly support the deletion of the language that may have led to a change in the unit structure or the reimbursement rate as crisis intervention is far less costly than higher level care intervention and is able to respond in a more timely and thorough manner spending time with the consumer until the crisis is abated without involving more costly and overwhelmed inpatient services. Making Non-Residential Crisis Stabilization services an eligibility criteria for follow-up MHSS services is a more cost effective and less cumbersome process without overwhelming the already overburdened healthcare residential system and greatly increases the consumer's access to needed mental health skills building follow-up care. 

CommentID: 42205