Extension of more mental health services to Virginia residents is always beneficial! Here are three proposals for amendments to the proposed language:

1. Pgs. 4-5, 7 of Appendix E; MH-IOP Level of Care Guidelines; Service Definition: “…A MH-IOP requires psychiatric oversight with at least weekly medication management included in the coordinated structure of the treatment program schedule.”
   1. Please consider revising this section to allow individualization of med management appointments, maintain a minimum of a monthly requirement. 

      Additionally, individuals commonly express a preference to use their primary care physician instead of a psychiatric provider, or the individual declines a referral for a psychiatric evaluation and medication management. In these scenarios, please consider allowing individuals to continue participation in MH-IOP. Providers should document the individual’s choice and preferences and also engage in service coordination with any outside prescriber.

2. Pg. 8 of Appendix E; MH-IOP Level of Care Guidelines; Service Limitations: “MH-IOP may not be authorized or billed concurrently with…Mental Health Skill-building …”
   1. Please consider allowing individuals to receive MHSS and MH-IOP concurrently, as they target different skills in differing locations.
3. Pg. 9 of Appendix #; MH-IOP Provider Participation Requirements: “Regardless of setting, these programs should not be disruptive of the school day or provides as part of the school day structure for youth participants.”
   1. Please consider allowing individuals to receive TDT and MH-IOP concurrently, as they target different skills in differing locations. The removal of TDT services from these individuals may result in change to more restrictive environments, including homebound instruction and movement to a private day placement. MH-IOP providers who coordinate services with TDT providers are more likely to see these skills generalized across service settings with the goal to successfully discharge from both programs.