BACKGROUND
The Virginia Association of Community-Based Providers (VACBP) was an early supporter of the enhancement of Virginia’s community-based behavioral health Medicaid services. As the association and our members have participated in the process, our focus has been on ensuring that the behavioral health system offers a continuum of care that:
PROVIDER MANUAL INPUT
As we approach the implementation of those phase one services that will be implemented on July 1, 2021, the VACBP offers the following input on the proposed provider manual changes currently under consideration. Thank you for the opportunity to have our input considered. Please note that all the comments provided are related to Mental Health – Intensive Outpatient (MH-IOP).
Medication management – The VACBP requests that the provider manual more clearly define what “medication management” means and that the requirement that psychiatric oversight include a minimum of weekly medication management be adjusted to a minimum of monthly medication management.
Rationale: This change will ensure there is a clear understanding of the specific expectations with respect to medication management and will provide flexibility so the provider can determine what is needed for and in the best interest of each individual patient.
Patient choice for primary care physician – The VACBP requests that an adjustment be made to allow individuals to continue participation in MH-IOP in cases where an individual may prefer to use their primary care physician or an external, established psychiatric provider instead of the psychiatric provider included within the MH-IOP staffing plan, or where the individual declines a referral for a psychiatric evaluation and medication management.
Rationale: This will reduce the barriers to receiving this service for those who may benefit from it but are more comfortable seeing an existing primary care physician. This also would enable those who decline a psychiatric evaluation or medication management to participate in MH-IOP. In these cases, the clinician should be required to document the individual’s choice and preferences and engage in service coordination with any outside prescriber.
Concurrent MH-IOP and MHSS – The VACBP requests that the prohibition on an individual’s ability to receive both MH-IOP and MHSS concurrently be removed.
Rationale: Many individuals admitted to MHSS could benefit from participation in a MH-IOP program. There are concerns that discontinuing the MHSS services would likely cause regression in the individual’s treatment progress. It’s also important to note that the hands-on, practical, and real-time skill-training provided to individuals in their home and community setting through MHSS is outside of the MH-IOP service scope. This may not apply to all patients, but flexibility should be provided to accommodate those cases where both treatments would be beneficial to the individual.
Concurrent MH-IOP and TDT – The VACBP requests that the prohibition on an individual’s ability to receive both MH-IOP and TDT concurrently be removed.
Rationale: There is concern that limiting concurrent MH-IOP and TDT service authorizations will result in youth who lack the support and intervention needed to function well during the school day and could result in more restrictive service interventions or school placements as a result. MH-IOP aims to significantly increase the youth’s healthy ability to cope, relate interpersonally, and problem-solve. 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. The inability to receive MH-IOP and TDT concurrently will likely result in youth and guardians who decline MH-IOP in an effort to preserve TDT services, forfeiting MH-IOP which may be a needed and beneficial service opportunity.
90-day assessments – The VACBP requests that additional information regarding what is expected to be documented in the assessment required every 90 days be provided and that providers are able to appropriately bill for the assessments.
Rationale: It is important that there be a clear understanding of what the expectations are with respect to these assessments and that providers can be reimbursed to provide it. This clarity can also help providers understand how the 90-day assessments will be used and the relationship between this assessment and other required service planning.
Accreditation requirements – In order to better prepare for continued enhancement of Virginia’s Medicaid behavioral health services, it’s important to understand DMAS’s vision with respect to accreditation.
Rationale: While a requirement that providers be accreditted is proposed in the case of MH-IOP, there is uncertainty as to whether the vision for the system is likely to include required accreditation for other services as enhancement continues. Given the long timeline and significant cost to becoming and maintaining accreditation, the VACBP requests greater transparency and clarity regarding potential future requirements with which providers will need to comply to provide services.
The VACBP urges the elimination or significant reduction of licensing regulations in those cases where a provider is accredited.
Rationale: With the requirement that agencies be accreditted in order to provide service, yet another layer of compliance requirements will be added to existing licensing and other related regulations. The VACBP and its members are committed to compliance with all applicable regulations and implementation of best practices to ensure providers are operating at the highest of levels. That being said, multiple layers of requirements are significantly increasing the administrative burden on providers and setting the stage for duplicative and potentially conflicting standards and requirements.
Where accreditation is required, the VACBP requests that the rates include all the associated costs, both direct and indirect.
Rationale: Even in the case of the rates for MH-IOP, the VACBP is concerned that the true and complete costs to obtain and maintain accreditation are not included in the rates. As there are further requirements imposed on providers, the true and complete costs should be accommodated in the rates.
The Virginia Association of Community-Based Providers (VACBP) is an association of private-sector organizations that provide community-based behavioral health and substance use disorder treatment to Virginia’s most vulnerable populations. The VACBP is among largest associations representing the interests of private-sector behavioral health providers In Virginia, with more than 50 agencies that have more than 160 facilities across the Commonwealth.
The association’s members range from providers with less than 10 employees to more than 500, from agencies with one location to more than 30, serving the behavioral health needs of individuals in all regions of the Commonwealth. Members of the VACBP provide a wide range of behavioral health and SUD services, including Intensive In-Home (IIH), Mental Health Skill Building Services (MHSS), Therapeutic Day Treatment (TDT), Crisis Stabilization (CS), Crisis Intervention (CI), Crisis hotline/texting services, Outpatient (OP), Applied Behavior Analysis (ABA), Psychosocial Rehabilitation (PSR), Supported Employment, Permanent Supportive Housing (PSH), Comprehensive Services Act (CSA)-funded services and Addiction and Recovery Treatment Services (ARTS).