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  9:13 am
Commenter: Randi Paxton

Missed the mark again

What a shame that regulations continue to limit access to care for our most vulnerable population!  In a time when so much work is being done to reduce the stigma associated with mental illness and when there seems to be a societal push to seek treatment when necessary, regulations prevent this forward movement with mental health services. 

Concerning the proposed regulation which states that an LMHP, LMHP- Supervisee, or LMHP- resident may complete, sign and date an ISP:  LMHPs/LMHP-Es continue to be difficult to employ in more rural parts of the state.  Ethically, it is not appropriate for someone who has not been working with a client consistently to write an ISP.  In order to truly involve the individual in the development of his ISP, it seems most appropriate that the QMHP-A assigned to the case, in conjunction with the individual, write the ISP as that person has the greatest knowledge of the challenges facing the client. 

Concerning the proposed regulation requiring an authorization for Crisis Stabilization:  Currently, it takes days to receive an authorization for other services.  The goal of Crisis Stabilization is to very quickly access the client and work with them to stabilize symptoms.  Waiting several days for an authorization will most likely lead to an increase in more costly services such as hospitalization and incarceration.  If providers were to begin providing services without this authorization, they risk providing services without reimbursement.  This proposed regulation severely limits access to care for mentally ill individuals. 

Concerning the proposed regulation concerning the number of days per week and hours per week required to carry out the goals in the ISP:  This seems to contradict the person-centered approach of services.  Clients' needs fluctuate a great deal over the course of services.  There are times when more services are required due to a significant stressor in a client's life as a means to prevent a higher level of care or ensure a client's safety.  Will providers be paid if they provide services outside of these prescribed levels set forth in the ISP? 

Concerning the regulation change in which Non-Residential Crisis Stabilization may be used as a higher level of care in the consideration of MHSS eligibility criteria:  This is a wonderful addition to the higher level of care criteria.  Non-Residential Crisis Stabilization is often used to help clients avoid hospitalizations or other costly services.  The services provided in this setting mirror those of Residential Crisis Stabilization but are often more attractive to clients who avoid residential treatment at all costs due to parental responsibilities or other obligations. 

I fully understand the economic impact of increased services over the past years as research has shown.  However, there are more sensible ways to ensure spending on mental health services are warranted.  Increased accountability for current regulations would significantly reduce the need for further regulations.  Increased and more targeted auditing practices would ensure individuals are receiving needed treatment while ensuring that Medicaid funds are being utilized appropriately.  Continuing to increase regulations and making it difficult for providers to provide these much needed services will only hurt those individuals in need of services in the end.

CommentID: 42309