Agencies | Governor
Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
Board
Board of Medical Assistance Services
chapter
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 Ends 10/23/2015
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10/23/15  4:58 pm
Commenter: Joanna Vernon

Proposed regulation changes for MHSS
 

Proposed regulation for Mental Health Skill-Building ISP development: (Pg 19 I #3):  the "LMHP, LMHP- supervisee, or LMHP- resident shall complete, sign and date an ISP within 30 days of the admission to this service"

 

Having an LMHP write the ISP would place undue financial hardship on organizations providing MHSS services. QMHPP’s do this well already and do it in consultation with LMHP’s.Proposed regulation for Mental Health Skill-Building ISP development: (Pg 19 I #3):  the "LMHP, LMHP- supervisee, or LMHP- resident shall complete, sign and date an ISP within 30 days of the admission to this service"

 

Having an LMHP write the ISP would place undue financial hardship on organizations providing MHSS services. QMHPP’s do this well (they see the client's more often) already and do it in consultation with LMHP’s.

Proposed Regulation for Mental Health Skill-Building proposed ISP hours per week (pg 19 I #3): "The ISP shall include documentation of how many days per week and how many hours per week are required to carry out the goals in the ISP.  The total time billed for the week shall not exceed the frequency established in the individual's ISP."

 

This regulation does not allow for fluctuation based on the individuals needs.  There are many things that could impact individuals needs that cannot be totally foreseen at the writing of the ISP, for example, the individual experiences some type of crisis or increase in symptoms.  Having a bit of a range in the hours that can be provided per week allows for the ebb and flow of real life.  Trying to predict it for a 3 or 6 month period also takes away the individual’s ability to decide each week if s/he wants a few more or less hours depending on how s/he is feeling.  

Joanna Vernon, Creative Family Solutions/Rescare

 

CommentID: 42331