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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10/19/15  12:40 pm
Commenter: Misty Disharoon, EHS

Proposed regulations relating to Mental Health Skills Building Services

I have worked in the mental health field for six years and have volunteer experience prior to paid work experience and have experience in a variety of scenarios and programs. 

I feel that if an LMHP or LMHP-like staff is required to complete ISP's, there will be more cost incurred by companies to pay staff with such credentials, which may in turn, decrease care in other areas of services.  The worrk involved in creating an ISP does not contribute to hours needed to obtain licensure and therefore would make obtaining LMHP staff more difficult due to already limited access to such individuals.  ISP's are designed to be person centered, which also makes it more difficult for an LMHP staff to complete as the LMHP is currently only present with the individual for a limited amount of time and cannot ensure that upon creation of the ISP, the client will be willing to participate in all areas of the ISP, which places the ISP at risk of taking longer to be approved and signed upon by both the client and the LMHP staff.

I feel that requiring an authorization for Crisis Stabilization Services is counterintuitive to the work that is to be provided by Crisis Stabilization clinicians as the point of providing such services is to assist the individual in decreasing costly hospitalizations or risk of harm to self or others.  If the Crisis Stabilization Service requires an authorization, the individuals will not receive prompt care and could be placed in a more restricted environment, such as hospitalization, which would increase the crisis upon discharge from hospitalization.  For a person in a crisis situation, a 2-5 day wait for authorization for Crisis Stabilization Services could be the difference between life or death.

I support the addition of Non-Residential Crisis Stabilization Services as a higher level of care in the consideration of MHSS eligibility criteria.  In order to be admitted to Non-Residential Crisis Stabilization Services, an individual must be approved through an assessment process by an LMHP or LMHP-like staff member.  Non-Residential Crisis Stabilization Services provide the same services as Residential Crisis Stabilization Services.  However, residential facilities are limited in our area.  There are benefits to receiving Non-Residential Crisis Stabilization Services that are not present in Residential Crisis Stabilization Services as the individual is learnign how to manage triggers to heightened symptoms in their live environment so that they are more capable of managing such stressors independently upon completion of the program.  The individual is receiving one-on-one training and linking to needed resources to decrease the risk of more costly alternatives, such as hospitalization, and are able to access such resources with the support of the clinician to create more comfortability in utilizing such resources upon the completion of the crisis program.

I appreciate your consideration in these matters and would like to request that the well-being of those that suffer with mental illness be considered in implementing proposed changes so as to not create an environment with decreased supports to those individuals, which can create the presence of increased social situations by individuals who are unable to receive needed care to learn mental health symptom management techniques.

Thank you.

CommentID: 42233