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  12:08 pm
Commenter: Jackie Weddle, EHS Support Services

Proposed Changes Mental Health

Organizations are likely to experience a financial hardship if required to hire LMPH/LMHP-like staff members to complete ISP’s.  MHSS providers will have a decreased applicant pool and as a result may go out of business.  LMHP’s (and like staff) prefer maximum face to face time with the client rather than increased paperwork.

Scott D. Miller, Ph.D. is the founder of the International Center for Clinical Excellence an international consortium of clinicians, researchers, and educators dedicated to promoting excellence in behavioral health services. In his article, Scott Miller’s research shows that a high documentation to clinical service ratio leads to higher rates of:

  • Burnout and job dissatisfaction among clinical staff;

  • Fewer scheduled treatment appointments;

  • No shows, cancellations, and disengagement among clients.

As reported by, there has been a 23.52 % increase for LMHP’s nationwide. Vacancies for this career have increased nearly 24% nationwide since 2004. An astounding additional 30,000 new jobs will need to be filled by 2018. These forecasted predictions should be motivation enough to reconsider the proposed requirement to mandate that our professionals spend additional time feeding the “bureaucratic paperwork beast”.  I agree with practices that insures accountability, however, it must be simultaneous with improving the services we provide to our clients.

Crisis Stabilization Authorization

Because mental health affects 1 in 4 adults each year (Leonard, 2014) it is vital that everyone not only has access to immediate mental health care, but have it in a timely manner. 


Miller, Scott (2014) Is Documentation Helping or Hindering Mental Health Care? Please Let me know

Leonard, Kimberly,(2014), Retrieved from:



CommentID: 42319