Over the last 5 -7 years there has been a shift in community mental health. Particularly in the last 6 months the shift for private providers dealing with not only DBHDS and DMAS regulations but also now MCO (managed care organizations) regulations has become the biggest administrative burden. While this town hall comment is not necessarily here for that topic it sets the stage for politicians to understand the climate of community behavioral health right now. The focus from true care to worrying about paperwork constantly for 3 (4 if you count human rights) different types of regulatory entities takes so much away from actually helping people. There should absolutely be regulations and rules to follow so that private providers like myself can follow ethical guidelines and demonstrate quality care. However, when the focus shifts from the client and what they need to meeting a deadline all the time it is very burdensome. ISP's should be revised. I tell my staff they are a working document. The burden of counting out exactly 90 days for a review and then ensure whether it snows, hails, sleets, etc we see them on the 90th day to get a signature and finalize review is really not therapeutic at all. If the focus was on the actual ISP and reviewing it as needs changed or even allowing for the administrative time to review it and obtain signatures around the 90 day period (maybe a 30 day grace period) then it may become a more useful document. There is no point in an ISP every 90 days when people are just doing it to do it and say it was done. If we had more flexibility as the provider to have more time to revise it, review it, and obtain signatures within a grace period than the quality of care I believe would increase. 

Now the only downfall to all of those thoughts are that the MCO's now want the ISP to accompany the Service Authorization request. Those requests go in every 90 days so you may run into issues if the ISP has not been revised in time. 

Overall, it sucks that all 4 entities plus MCO's are not on the same page at all about regulations that are in black and white and those that we are trying to serve are greatly affected by it. People being denied for services left and right because they have had them for "too long" or "the service failed"... after 18 months. I have so many "stories" that are real clients lives that are being affected by these ridiculous decisions. Big money companies are just trying to save the government money. I envision within a few years we will be back like the settlement days with mentally ill individuals walking the streets and homeless. That is the direction we are headed. So while I applaud the opportunity to correct an administrative time crunch there are some really big issues at stake in our community behavioral health world.