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  12:12 pm
Commenter: T. Thornhill Jones BS, QMHP

Proposed changes

There seems to be an ongoing urgent need to change criteria and services for Mental Health Skill Building and Crisis Stabilization services without much aforethought for the clients receiving the services or the providers that continue to provide an ethical professional service to the community.  Clients depend on Skill Building services to meet their needs and to learn to live independently while struggling with Mental Illness, limited financial resources, very little primary support, co-occurring substance abuse issues and homelessness just to name a few.  These are individuals who rarely know about the changes and are often dismayed, disappointed and frustrated when changes are submitted.

One of the proposed changes is for a Licensed person  or a person seeking Licensure to complete all of the ISP's for the clients served by an agency.  While this is completely contrary to the changes made a couple of years ago when the decision was made that QMHPP individuals can provide direct care to clients. This implies that you can have less experienced or educated individuals to work daily with the clients in the home and in the community, but then a Licensed Professional would be required to write the ISP's.  This would mean that ISP's are written by someone who has very little contact with the client and clinicians pride themselves in having the clients involved with their treatment.  

My other concern (while there are many), would be that Crisis Stabilization services would no longer be registered but would require an authorization. Authorization take anywhere from 2-5 days, what about the care of the client in the meantime?  The registration process at is now, is working for Crisis Stabilization, but requiring an authorization would delay the service, deter clients from admission, and jeopardize the safety of many individuals.

I suggest that before changes are made that clients, providers and community partners come to together to discuss what makes sense in the community and on behalf of our Mentally Ill population, who feel at times that they do not have a voice.

Concerned in Virginia,

T. Thornhill Jones

CommentID: 42320