Due to the ongoing staffing crisis and limitations of availability of in-person staff. Remote Supports should be an option for service delivery on this waiver.

William McFarlane's work on early psychosis and long-term recovery in Schizophrenia, particularly from the negative symptoms of serious mental illness with ongoing family support, has been seminal in the field.  McFarlane and his collaborators cite study findings that suggest substantial decrease in the relapse rates of those recovering from 1st and 2nd episodes of psychosis with early pharmacological intervention with evidence of sustained recovery.  Dr. McFarlane's cites research, as well, describing the improved prognosis for recovery over time that has been shown to vary with the degree of family support and participation delivered at home and in the community in the improvement of negative symptom in adults diagnosed with Schizophrenia.  The Multiple Family Support treatment model, championed by McFarlane et al, in care coordination with other evidence-based, home-based treatment models, such as Assertive Community Treatment (ACT) and Crisis Resolution In Home Treatment (CRIHT), have been shown consistently to be effective in international studies in sustaining long-term recovery in these chronic "at risk" populations.  Home-based psychiatric care delivery enhanced with "point of care" and remote medical technologies represent potential alternatives to hospital and clinic based psychiatric care that should be taken into account for services provided along a broad continuum of care.  Such "state of the art" innovations of care should be fully taken into account in DMAS Bravo's enhanced funding initiatives under the Medicaid Waiver 1115 SMI proposals and should be comparable in scope under mental health parity law to those funded for SUDS and Co-morbid disorders under the ARTS Waiver programs and Opioid settlement.

In Service.

Edmund W. Creekmore, Jr., PH.D., LCP, National Shattering Silence Policy Action Co-Chair and Virginia Policy Director

There is a clear need to continue the 1115 Demonstration waiver in Virginia. Virginia is home to over 5,000 children in the foster system as of Spring 2024 (Virginia DSS). Substance use rates of use vary by estimate with approximately 5.6% of Virginians abusing alcohol and 7-9% abusing illicit drugs (SAMSHA/hhs.gov & Kaiser Foundation). As a medical social worker who witnesses daily the intersection of mental and physical health, I support renewal of the application to CMS as one tool to provide the most possible resources for Virginians who find themselves facing potential or actualized mental illness.

I support the continuation of the 1115 waiver for individuals with SMI (Serious Mental illness). It will be important for the General Assembly to continue to support the DBHDS (Department of Behavioral Health and Disability Services) in rental subsidies and services to provide housing to very low-income people with SMI (Serious Mental Illness), which will be critical moving forward. Additionally, being able to have access to behavioral health care is critical for individuals with SMI, and having early prevention and management services that are personalized to their needs would be very essential, particularly with children and youth.  Therefore, community-based services and inpatient and outpatient facilities need to continue incorporating people with disabilities (PWDs) that have SMI providing accommodations, which can include sensory-friendly spaces and specialized staff training to meet the needs of PWDs. Since the wavier is coordinating transportation to appointments, there should be an increase in provider development to ensure capacity can meet the need.

It is imperative that School Divisions, and especially via IEP Teams are REQUIRED to adhere to and follow the Advice of a students MDs regarding Medical Information, Health Plans, etc. There is a tremendous amount of Medical Neglect being performed by School Divisions refusing Medical Advice for students and resulting in Educational Neglect. School Divisions/School Boards who are NOT in the Business of Medicine, must NOT refuse to adhere to Medical Advice by qualified Medical/Mental Health Providers submitted to the School Divisions. 

There MUST be a look-back period of accountability, going back no less than 10 years and stiff penalties to individuals AND School Boards refusing to fully acknowledge and implement/provide for the medical needs of students. Suggested penalties are $10,000 per 'individual' on an IEP 'Team' who refuses Medical Advices per occurrence, AND $50,000 penalty to the School Board per each offending occurrence to be paid DIRECTLY to the Student/Family net 30. LOOK how much each LEA pays to Sands Anderson. They keep children OUT of Education often by REFUSING to provide for a child's Medical Needs. 

The Federation of Virginia Food Banks is leading a coalition of more than 70 public, private, and nonprofit organizations committed to advancing Food is Medicine initiatives in the Commonwealth. We support the proposed 1115 demonstration waiver and ask that it be expanded to include nutrition programs for the target population.

CMS has identified food insecurity as the number one SDOH (Social Determinant of Health) need among Medicaid members nationwide. Five other states have implemented or requested waivers to provide nutrition support to Medicaid member w/ Serious Mental Illness. If Virginia’s goal is “to improve access to community-based services so that the full continuum of care is available to meet the needs of Medicaid members with Serious Mental Illness (SMI)” then food should be included as a defined service category.

 The SMI population is at high risk for food insecurity and therefore more likely to suffer from the associated negative health consequences. A recent meta-analysis shows that adults with SMI were 3.31 (95% CI: 2.03 to 5.41) times more likely to experience food insecurity than comparators without SMI (Smith Et al., 2023). 

The Federation and its partners have significantly expanded our capacity to manage referral coordination and connect patients to services across our statewide network of 1,100 agency partners, including SNAP application assistance and/or direct service delivery. We stand ready to support the successful implementation of the waiver and ensure all Medicaid members have access to the services they need to support healthy outcomes.

Connections Health Solutions strongly supports the proposed 1115 Serious Mental Illness Waiver  Amendment Application submitted by Virginia Department of Medical Assistance Services (DMAS).  We appreciated that it specifically references the Prince William County Crisis Facility and Programs.

Thank you to the many DMAS staff who have contributed to the effort to get the draft application prepared and ready for comment so quickly; in order to implement Governor Youngkin’s Right Help Right Now initiative and meet the many needs for effective and timely access to crisis services for both youth and adults, it will be critical to minimize the barriers to service.

We look forward to working with DMAS to ensure Medicaid support for its community-based crisis stabilization program.  Our planned Woodbridge Crisis Response Center is on track to open in 2025.  It will accept all individuals 24/7/365 experiencing a behavioral health crisis becoming the first center to fulfill the Right Help Right Now initiative.  It will offer walk-in behavioral health urgent care and extended stabilization units for youth and adults; regardless of ability to pay. 

The goals of the Demonstration as listed in Section III are appropriate and the Crisis Now model of care has proven effective in achieving the goals of reducing both utilization and length of stay in ERs, reducing preventable readmissions, and adding to the continuum of community crisis care as well as reducing wait times for law enforcement.

We thank DMAS officials for including accreditation through The Joint Commission as well as the other quality measures described will help to assure that the services provided are of the highest standard. 

Required in our contract with the Prince William Community Services Board, we will collaborate to improve the Care Coordination and facilitate the transition to other levels of community-based care.  We look forward to the dynamic involvement of the MCOs in this effort as well.

Short term stabilization beds are essential to the “No Wrong Door,” mission accepting 100% of individuals; particularly from law enforcement in the smoothest possible manner.  Additionally, without Medicaid’s involvement, this center would cost Commonwealth and county taxpayers 100% more to fund the system and result in more costly fragment care by multiple providers. This approach ensures Medicaid’s participation in Virginia’s crisis system given Crisis Stabilization programs are intended to prevent the need for institutional care as this waiver application assures. 

For the record, the Social Security Amendment of 1972 (P.L. 92-603) provides an IMD exception for children under the age of 21.  We urge Virginia to incorporate and expand upon Medicaid coverage of inpatient psychiatric services for individuals under the age of 21 into its program. Section 4930 of the State Medicaid Manual describes the criteria states must take into consideration when determining IMD status.

We appreciate DMAS for advancing these critical reforms and moving quickly with this vital waiver, and we look forward to collaborating and partnering on efforts to ensure that youth and adults experiencing behavioral health crises in our county receive the care and support they deserve. 

Thank you again.

As a resident of Prince William County, I thank the DMAS staff for so quickly readying the proposed 1115 Serious Mental Illness Waiver Amendment Application for comment and submission. This Waiver Amendment specifically references the Prince William County Crisis Receiving Center (CRC), which has been determined an IMD by DMAS. If approved by CMS, it will help ensure that our loved ones—whether adults or youth--can have timely and effective access to appropriate mental health and substance use services. Our community is proud that this CRC will be the first center implementing Governor Youngkin’s “Right Help, Right Now” initiative and that this Waiver Amendment will assure that in the future, walk-in behavioral health urgent care and extended stabilization units are available for youth and adults, regardless of ability to pay, at other locations the Commonwealth.

Short term stabilization beds are essential to the “No Wrong Door” mission of accepting 100% of individuals, particularly from law enforcement. They are also intended to help prevent the need for institutional care outside the family and local community support system. Currently, our county has the largest number of residents needing to go outside our region to access inpatient care under a TDO order. Additionally, without Medicaid reimbursement, this center would cost Commonwealth and county taxpayers much more and result in very expensive, fragmented care by multiple providers.

The Crisis Now model of care should reduce the use and length of stays in ERs as well as wait times for law enforcement. It may also reduce incarceration rates in our local ADC for persons with behavioral health issues. Co-located Community Services program support staff on site will ensure follow-up care and reduce preventable readmissions.

I also hope that Virginia will recognize the IMD exception for persons under the age of 21 (Social Security Amendment of 1972, P.L. 92-603) and incorporate and expand Medicaid coverage for inpatient psychiatric services for children and youth.

As a resident of Prince William County, I want to express my appreciation to DMAS for the prompt development of the proposed 1115 Serious Mental Illness Waiver Amendment Application. This waiver amendment is critical for ensuring the Prince William County Crisis Receiving Center (CRC) can deliver on its promise to provide timely, accessible mental health and substance use services for both youth and adults.

The CRC represents a transformative step forward in behavioral health care for our community. It aligns with the “Crisis Now Model,” which prioritizes local care, immediate access, and stabilization, reducing the need for hospitalization or involvement with the criminal justice system. However, the determination that the CRC is classified as an Institution for Mental Disease (IMD) jeopardizes its ability to offer vital services due to the lack of Medicaid funding.

Medicaid reimbursement is essential to ensuring that the CRC can operate sustainably and meet the needs of our community. Without it, the financial shortfall threatens the availability of critical services, particularly for youth, who are already underserved.

The 1115 waiver amendment is a vital solution. By enabling Medicaid coverage, it would reduce the burden on local law enforcement, emergency rooms, and taxpayers while ensuring care is accessible and effective. The inclusion of short-term stabilization beds and co-located follow-up services will provide much-needed support for individuals and families, reducing the need for out-of-area placements and strengthening our local community's support network.

I also urge Virginia to consider expanding Medicaid coverage for inpatient psychiatric services for children and youth, recognizing the importance of addressing mental health needs early and comprehensively.

I strongly support this waiver amendment and its goal to eliminate barriers to care for some of our community’s most vulnerable individuals. Thank you for the opportunity to share my input and advocate for the health and well-being of our community.

I am writing in strong support of the DMAS's proposed 1115 Serious Mental Illness Waiver Amendment Application.  This Waiver Amendment specifically references the Prince William County Crisis Receiving Center (CRC), which has been determined an IMD by DMAS.  If approved by CMS, It will help ensure that our loved ones—both adults and youth–can have timely and effective access to appropriate mental health and substance use services .  Our community is proud that this CRC will be the first center implementing Gov. Youngkin’s “Right Help, Right Now” initiative and that this Waiver Amendment will assure that in the future, walk-in behavioral health urgent care and extended stabilization units are available for youth and adults, regardless of ability to pay, throughout the Commonwealth.

 Short term stabilization beds are essential to the “No Wrong Door” mission of accepting 100% of individuals, particularly from law enforcement.  They are also intended to help prevent the need for institutional care outside the family and local community support system. Currently, our county has the largest number of residents needing to go outside our region to access inpatient care under a TDO order.  Additionally, without Medicaid reimbursement, this center would cost Commonwealth and county taxpayers 100% more and result in very expensive, fragmented care by multiple providers. 

The Crisis Now model of care should reduce the use and length of stays in ERs as well as wait times for law enforcement.  It may also reduce incarceration rates in our local ADC for persons with behavioral health issues. Co-located Community Services program support staff on site will ensure follow-up care and reduce preventable readmissions.

I also hope that Virginia will recognize the IMD exception for persons under the age of 21 (Social Security Amendment of 1972, P.L. 92-603) and incorporate and expand Medicaid coverage for inpatient psychiatric services for children and youth.

 Thank you again for this opportunity to voice my strong support for the 1115 Serious Mental Illness Amendment Application.

Sincerely,

James Pearlstein

Virginians Organized for Interfaith Community Engagement (VOICE)

I am writing in support of the DMAS's proposed 1115 Serious Mental Illness Waiver Amendment Application.  This Waiver Amendment Specifically references the Prince William County Crisis Receiving Center (CRC) which has been determined an IMD by DMAS. 

As community members, we wring our hands when mentally ill youth open fire in our classrooms, yet we fail to provide them with the care they need when they are in crisis.  Many of us have suffered through a crisis with a family member, when our only option was the Emergency Room or law enforcement.  As I understand it, Medicaid reimbursement is essential to ensuring the Prince William County CRC can operation sustainably.  Walk-in mental health and stabilization unit services should be available for citizens throughout Virginia regardless of their ability to pay.  

I urge you to issue DMAS's proposed 1115 Serious Mental Illness Waiver Amendment so the CRC in Prince William County can become a model throughout Virginia of a facility that can help address the crisis in mental health that has touched all of us one way or another.  

Thank you

As a former teacher in Prince William County Schools and the parent of a child who has had a severe mental health crisis in the last year, I urge you to support and pass the 1115 Serious Mental Healthy Waver Amendment.  The proposed Prince William County Crisis Receiving Center in Woodbridge is so needed for kids and young adults up to 21.  If you are unsure as to the importance of this Waver, please reach out to myself or other Virginia Parents who have had to find emergence care in our area.   

Respectfully,

Susan Dommer

As a resident of the City of Manassas, I want to support the proposed 1115 Serious Mental Illness Waiver Amendment Application.  This Waiver Amendment specifically references the Prince William County Crisis Receiving Center (CRC), which has been determined an IMD by DMAS. It will help ensure that our loved ones have access to appropriate mental health and substance use services. This Waiver Amendment will assure that in the future, walk-in behavioral health urgent care and extended stabilization units are available for youth and adults, regardless of ability to pay, Short-term stabilization beds are essential to the “No Wrong Door” mission of accepting 100% of individuals, particularly from law enforcement. 
The Crisis Now model of care should reduce the use and length of stays in ERs as well as wait times for law enforcement. It may also reduce incarceration rates in our local ADC for persons with behavioral health issues. Co-located Community Services program support staff on site will ensure follow-up care and reduce preventable readmissions.
I also hope that Virginia will recognize the IMD exception for persons under the age of 21
(Social Security Amendment of 1972, P.L. 92-603) and incorporate and expand Medicaid
coverage for inpatient psychiatric services for children and youth. Thank you for this opportunity to voice my strong support for the 1115 Serious Mental Illness Amendment Application. This is a very important issue to the community and will impact so many families and individuals in a crucial way.    
Sincerely, Lisa Nouri

Individuals with serious mental illness (SMI), outside the supports of permanent supportive housing (PSH), may present with additional health related social needs (HRSNs) that also need to be coordinated in order to promote success. Medical and mental health, coupled with social health, are a whole health approach to supporting individuals with complex need.

The waiver language under Milestone 2.b recognizes that “Connecting members to housing resources also helps to drive down ED utilization. Several MCOs reported that members with a SMI diagnoses and housing instability often present at the ED as a means of temporarily accessing shelter and food. MCOs will continue to engage CSBs and other stakeholders across the housing continuum to understand and proactively address member housing needs in the most appropriate setting possible.”

Creative housing options to support transitions, and the coordination of services to access HRSNs remains a barrier. There is a need for waiver language around medical transition housing to support transitions from the emergency department and/or inpatient stays. Patients may need a place to be safe and heal prior to entering into PSH environments. Additionally, language supporting community care hubs or backbone organizations that enable successful access to HRSN resources in the community will help sustain patients in the community. Infrastructure to empower mission critical community partners that serve HRSNs through the coordination of supports would supplement the care needed for the SMI population being addressed.

Dear Dr. Jobes-Shields,

On behalf of my office, and the constituents of the Occoquan District in Prince William County, I am writing to express my strong support of the proposed 1115 Serious Mental Illness Waiver Amendment Application submitted by the Virginia Department of Medical Assistance Services (DMAS).  This waiver is vital in ensuring that the Prince William County Crisis Facility and Programs can provide these needed services for youth and adults and bill full Medicaid. By not allowing facility operations to bill Medicaid, the status quo would adversely impact some of our most vulnerable residents and add additional financial burdens to the County.

The mental health crisis our communities face is far from new, and the Crisis Facility is a much-needed step in addressing that crisis. As the facility is in the district I represent, I know its strategic location and unique operating structure will provide life-changing – and life-saving – services for families with no current local crisis care options.  Prince William County experiences the highest number of residents needing to go outside of our region to access inpatient treatment while under a temporary detention order. This current dynamic can draw away law enforcement resources, place individuals far away from their families and communities, and lead parents to give up on trying to get their children the mental health resources they need.

In short, the Prince William Crisis Facility and Programs are a game-changer for our community, and we need your assistance to ensure it can deliver the best possible services to the widest population of our residents.

I appreciate DMAS for advancing these critical reforms and moving quickly with this vital waiver, and I look forward to collaborating and partnering on efforts to ensure that youth and adults experiencing behavioral health crises in our county receive the care and support they deserve.

In service,

Kenny Boddye
Occoquan District Supervisor

As a resident of the City of Manassas, I am writing in strong support of the DMAS's proposed 1115 Serious Mental Illness Waiver Amendment Application. I thank the DMAS staff for so quickly preparing the proposed application for comment and submission.  This Waiver Amendment specifically references the Prince William County Crisis Receiving Center (CRC), which has been determined an IMD by DMAS.  If approved by CMS, it will help ensure that our loved ones—whether adults or youth—can have timely and effective access to appropriate mental health and substance use services.  Our community is proud that this CRC will be the first center implementing Governor Youngkin’s “Right Help, Right Now” initiative and that this Waiver Amendment will assure that in the future, walk-in behavioral health urgent care and extended stabilization units are available for youth and adults, regardless of ability to pay, at other locations the Commonwealth.

Short-term stabilization beds are essential to the “No Wrong Door” mission of accepting 100% of individuals, particularly from law enforcement. They are also intended to help prevent the need for institutional care outside the family and local community support system. Currently, our county has the largest number of residents needing to go outside our region to access inpatient care under a TDO order.  Additionally, without Medicaid reimbursement, this center would cost Commonwealth and county taxpayers much more and result in very expensive, fragmented care by multiple providers. 

The Crisis Now model of care should reduce the use and length of stays in ERs as well as wait times for law enforcement.  It may also reduce incarceration rates in our local ADC for persons with behavioral health issues. Co-located Community Services program support staff on site will ensure follow-up care and reduce preventable readmissions.

I also hope that Virginia will recognize the IMD exception for persons under the age of 21 (Social Security Amendment of 1972, P.L. 92-603) and incorporate and expand Medicaid coverage for inpatient psychiatric services for children and youth.

As a former foster dad of a young adult with mental illness and addiction issues, this center is needed now for him and others like him.

 Thank you again for this opportunity to voice my strong support for the 1115 Serious Mental Illness Amendment Application.

Sincerely,
Mike Freeland

As a resident of Prince William County, I thank the DMAS for so quickly readying the proposed 1115 Serious Mental Illness Amendment Application for comment and submission. Our community is proud that the Crisis Receiving Center (CRC) will be the first center implementing Gov. Youngkin's "Right Help. Right Now" initiative and that this Waiver Amendment will assure that walk-in urgent behavioral health care and extended stabilization units are available for youth and adult patients, regardless of ability to pay.

Short-term stabilization beds are essential to the mission of accepting 100% of individuals, particularly from law enforcement. They are also intended to help prevent the need for institutional care outside the family and local community support system. Without Medicaid reimbursement, the center would cost Commonwealth and county taxpayers much more.

I also hope that Virginia will recognize the IMD exception for persons under the age of 21 and incorporate and expand Medicaid coverage for inpatient psychiatric services for children and youth.

Thank you for the opportunity to voice my strong support for the 1115 Serious Mental Illness Amendment Application.

Sincerely,

Robert Allen

15505 Laurel Ridge Road

Dumfries, VA 22025

ragjar70@gmail.com

Good evening,

Mental illiness is on the radar.  I have a son with a mental illiness, therefore it is very important and dear to my heart.  Help is needed to open the Crisis Receiving Center during Summer 2025.  This is very important we can't wait two more years for a decision regarding funding from Medicaid. 

As a resident of Prince William County, I thank the DMAS staff for readying the proposed 1115 Serious Mental Illness Waiver Amendment Application for comment and submission.  This Waiver Amendment specifically references the Prince William County Crisis Receiving Center (CRC), which has been determined an IMD by DMAS.  If approved by CMS, it will help ensure that our loved ones—whether adults or youth—can have timely and effective access to appropriate mental health and substance use services.  Our community is proud that this CRC will be the first center implementing Governor Youngkin’s “Right Help, Right Now” initiative and that this Waiver Amendment will assure that in the future, walk-in behavioral health urgent care and extended stabilization units are available for youth and adults, regardless of ability to pay, at other locations the Commonwealth.

Short-term stabilization beds are essential to the “No Wrong Door” mission of accepting 100% of individuals, particularly from law enforcement. They are also intended to help prevent the need for institutional care outside the family and local community support system. Currently, our county has the largest number of residents needing to go outside our region to access inpatient care under a TDO order.  Additionally, without Medicaid reimbursement, this center would cost Commonwealth and county taxpayers much more and result in very expensive, fragmented care by multiple providers. 

The Crisis Now model of care should reduce the use and length of stays in ERs as well as wait times for law enforcement.  It may also reduce incarceration rates in our local ADC for persons with behavioral health issues. Co-located Community Services program support staff on site will ensure follow-up care and reduce preventable readmissions.

I also hope that Virginia will recognize the IMD exception for persons under the age of 21 (Social Security Amendment of 1972, P.L. 92-603) and incorporate and expand Medicaid coverage for inpatient psychiatric services for children and youth.

 Thank you again for this opportunity to voice my strong support for the 1115 Serious Mental Illness Amendment Application.

Sincerely,

Janie Harris