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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10/23/15  8:57 am
Commenter: Christine Morris

Proposed Changes

Concerning proposed changes to completion of MHSS ISP-

These changes are concerning as they do not reflect a person centered approach to treatment planning and providing services. An ISP is meant to be a working document created with an individual receiving services and those providing direct support. QMHP-A staff are qualified to develop and write treatment plans and gain invaluable experience through the development of an ISP with a client. As a Licensed Eligible professional it is concerning to me that this change would possibly be challenging to get hours that count towards licensure due to added responsibility of completing ISPs which does not count towards approved hours. Also, individuals receiving services would suffer as companies would struggle to maintain stability and offer person centered, sustainable services.


Concerning proposed changes to registration for Crisis Stabilization Services-

Unlike other services such as MHSS and Psychosocial Rehabilitation, Crisis Services are meant to provide immediate stabilization for individuals experiencing an acute crisis event. Making changes that require a pre-authorization for services would not allow service providers to immediately respond and work with an individual in crisis when the crisis event occurs. Crisis events are not planned and therefore it is unreasonable to expect a pre-authorization for this services. If immediate services are unable to be provided this will increase the use of psychiatric hospitals and utilization of the Emergency Room. Crisis Stabilization services should be used as a community based services that deters hospitalization and immediate response is required in order to ensure the safety of individuals receiving this services. In order to provide immediate, quality services, mental health agencies need to ensure that reimbursement is available from the service start date. It is concerning that the quality of mental health services that are tailored to prevent hospitalization could suffer if this proposed change is passed.

CommentID: 42306