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
10/22/15  3:37 pm
Commenter: K. Lee

concerns for propsed changes


The proposed changes to mental health skills building services are concerning for a number of reasons.  The more restrictions to community based services impact the clients who are in need across the state.  As a LPC, I understand the difficulty that up and coming professionals are facing when trying to meet the requirements of the Counseling Board as well as DMAS and the state regulations.  This poses a serious disadvantage to agencies that will not be able to hire the staff needed to comply with these proposals.  Also, living and working in more rural areas, there are significantly less licensed individuals to fill the required positions, which would negatively impact client’s ability to access services.

As part of my responsibilities I currently provide crisis stabilization assessment services.  It is inconceivable to be able to place a client who is currently on hold while we request approval.  The current timeline for receiving authorizations for other services is up to 5 days.  There are times clients are at risk of harming themselves or others and it would be unethical to postpone services in order to receive an authorizations. 

There has been a significant trend of encouraging community based services and use of community service board over residential treatment facilities.  Therefore many clients have received outpatient crisis stabilization services rather than inpatient services.  Clients should be able to count outpatient crisis stabilization services since the services is the same, just provided in a different setting.   

CommentID: 42286