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
10/21/15  3:56 pm
Commenter: Charles, Citizen SW Virginia

Proposal Commentary

I am a non-clinical, business professional residing in Southwest Virginia. Over approximately the past five years, I have had the opportunity to become a more active member and advocate for the mental health community within the Roanoke Valley and its surrounding areas.

It is my firm belief that any proposed regulation changes should solely be made in the spirit of improving the system with minimal impact to its constituents. I am unsure if this Virginia is practicing this credo.

I have followed regulation proposals for Mental Health legislation in Virginia and I am noticing an alarming trend. There exists countless instances in which reactionary proposals continuously spew out with careless impact analysis for the sole reason to immediately mitigate the financial damages of a broken system. This ideology will not work.

If the primary reason for reactionary regulation proposals is ultimately for financial recapture (as I personally believe it is), then I propose that Virginia end this archaic system of thinking and adopt a proactive approach by implementing a more efficient auditing process with stricter consequences for the agencies and individuals who abuse the system.

That being said and in light of responses I have so far read, this is my feedback concerning this round of regulation proposals.

Proposal - LMHP, LMHP supervised, or LMHP resident completes, signs, and dates ISP

To begin, Southwest Virginia as well as many other parts of Virginia does not have the human capital available to effectively allow this proposal to be passed. Of the little capital that is available, I would highly doubt the individuals who pursued this next-level of licensure had dreams of filling out countless stacks of paperwork. The QMHP individual’s credentials seem more than adequate to fulfill the needs of completing an ISP and this is the individual who is working with the patient on a daily basis. This concept would be similar to a personal trainer to completing a client’s fitness plan, seems appropriate.

Proposal - Crisis services requiring an authorization

The definition of a crisis is “a time of intense difficulty, trouble, or danger.” I do not support the requirement of an authorization for crisis services. The very nature of a crisis situation elicits an immediate response. This service cannot be effectively administered with the delay of big brother approval.

Proposal – Non-Residential Crisis Stabilization as qualifying higher level care criteria for MHSS eligibility           

I support this proposal to regulation. As current legislation allows Residential Crisis Stabilization as a higher level of care criteria, I believe that Non-Residential Crisis Stabilization should apply as higher level of care criteria as well.     

CommentID: 42255