I would urge decision makers to think critically about the overall goals/results to be achieved and utilize the latest research in determining how to adminstrate behavioral health benefits to Virginia Medicaid consumers. With the addition of Magellan, a forward-thinking and long established MCO, we have an opportunity to truly shape services that will result in lower cost, higher efficiency, and outcomes-oriented services.  For years, Virginia has mandated a one-size fits all, prescriptive approach to inpatient psychiatric residential treatment and community based group homes. This is in lieu of the emergence of evidence-based practices for specific patient populations and profiles that suggest better outcomes when treatment is specifically tailored to individual needs.  It seems that the regulation re-writes have been more focused on preserving most of what has already been in place (with a few inconsequential concessions) instead of focusing on how to reconcile the diverse needs, innovation in the marketplace, and outcomes in these levels of care. Intellectually disabled youth with co-occurring mental illness are not going to respond to insight-oriented therapies just as high functioning youth with addiction aren't going to respond to applied behavioral analysis.  A prescriptive approach strangles innovation and diverts resources. Programs are forced to orient their services and resources around following the prescription, instead of having the freedom and flexibility to find whatever works and achieve optimal outcomes for individual patients.  The result has been a system-wide focus on compliance as a means of providing patient care instead of effective patient care as a means of delivering positive outcomes for youth who require more intensive psychiatric treatment.  As a partner in serving those with significant behavioral health needs, there are enough expertise on the provider and payor side of things to create a system of care that is cost-effective, evidence-based, and outcomes-oriented.  The regulations, as written, prescribe frequency and intensity levels that are applied across the state, across all level B/C programs and patient populations, and without regard to innovation or flexibility within the system, much less any evidence based practice approach.  If the goal is truly efficient and effective behavioral healthcare for an entire cadre of youth in Virginia, providers must be given the flexibility to achieve the desired results and be accountable to those results.  These regulations make us accountable to the prescribed process, not the outcomes that could be achieved with a collaborative care model and truly individualized services.   The arbitrary requirements do not truly speak to the need for individualized programming.  I would recommend that the Behavioral Health Services Administrator be granted the authority to review each Service Authorization Request, and review admission and continued stay based on the programming that is being proposed by the provider.  Allow the provider to justify their clinical decisions and create the environments that improve the mental health of the individual.  Active treatment should be the focus of care.  To this end, I also recommend that we consider speaking with individuals here in Virginia that receive services.  Seek their feedback regarding the current regulations and treatment regimen.  How do they feel about the current academic and therapeutic structure while in treatment?