I would like to bring attention to numerous comments that have been on-going for many months at this location:

http://townhall.virginia.gov/L/ViewComments.cfm?stageid=6034s

To restrict access to MHSS services by increasing t he criteria for admissions to such a level that 65% of the MHSs clients will not qualify is to destroy anyone and chance that those serviced (at risk individuals and impacting families/children) of every getting out of their circumstances, becoming stable, obtaining or holding a job by increasing their stability and having supports to maintain jobs by continuing to work on coping skills and to change the quality of their lives. They will not be able to integrate into a different community due to being kept in their same circumstances.

To require psychotropic medications of a population that is fearful of telling psychiatrist the truth, and others in traditional settings, the truth based on a long history of having their children removed, being investigated by CPS, being institutionalized into hospitals or incarcerated makes this population often skeptical and fearful to tell the full truth of their circumstances. Many clients come to MHSS and their psychiatric visits do not reflect what they have shared during the MHSS assessment or with the QMHP worker. Upon inquiry they state they were fearful to tell those in traditional settings as they felt they had the power to “lock them up”, label them as “crazy”, and to “take my children”.  So now there will not be any place for them to share the truth in order to get the help they sorely need in order to change their lives and ultimately another generation.

The new reg’s are now more focused on skill building and that is great yet removing the support element is removing what they need for reinforcement of functional skills.  There is also a hyper focus on psychotropic meds and they must have been on them or had them prescribed in the last 12 months. Many clients are also fearful of meds, been told by their communities you are crazy for taking them, their diagnosis make them paranoid of such, or other issues connected to their MH and w/o services they cannot overcome these obstacles. Without MHSS and assistance to overcome resistances they will remain at peril to themselves and their families and children as well as ultimately to being cared for by the state in numerous forms of assistance, hospitalization, incarceration, etc.  Also to regulate only certain diagnosis obtaining services or having a psychiatric document why someone w/o those diagnosis needs services is to, as explained above, to keep many from services.

This a population that cannot just go see a therapist due to location and lack of transportation, lack of Care Vans that show up let alone get them there on time. They lose doctors and therapist due to being late, no shows, etc., and excuses are not accepted as to why they missed the sessions for the 1^st or 2^nd time and they are refused services. This population is often unable to maintain housing and will present the State and this City with more homelessness of families and children.

How can psychiatrist approve of services when they do not know that the client has ADL’s issues yet gives the appearance of not having any issues or fears telling the truth. They psychiatrist is not in their home to see the environment, that health and safety issues are a concern and that nutritional standards are not met, the refrig and cabinets are empty and that they cannot pay their bills on time.  There are current reports by psychiatrist stating the client has no ADL issues but they have a host of them documented repeatedly by actually being in the home. Client may even want to tell the MHSS assessor that they are fine in all those areas but the home tells the truth and with some prodding and assistance the client does come around to admission of the full extend of the issues.  Yet this is based on relationship of seeing the person time and time again in intensive forms and not just .5 or 1.0 a month. What a person says in an assessment or in one appointment is just the tip of the iceberg. Being more involved in their lives gives access to critical information that most of those with MH issues feel they must hide but once exposed, and not judged, they realize they can admit it and get help. The issues these client have is based on keeping secrets, being paranoid, fear that is realistic as well as unrealistic fears, being too depressed to remember in an hour or half hour what is going on and all they are experiencing. 

There are also no references to LMHP-E’s in the new regulations leading one to believe that they are not considered as viable options in providing services at a reduced cost operating under a LMHP. This is an increased cost while admissions shrink by 65-70%, rates decrease, and changing regulations take additional staff and admin time to uphold the changes, the increased cost for getting clients approved upfront, etc. The reg;s requested input on how this will impact small business/agencies in Virginia. This is a huge impact. Not only will clients be impacted and families but small business, that make up most of MHSS services, in Virginia. Thereby impacting employees with loss of jobs, loss of benefits for any agencies that can currently provide such, loss of agencies, loss of state revenue, etc. 

The new reg’s will cause escalating expenses as well for hospitalizations, increased crime, incarceration, recidivism, and disenfranchising those with the greatest risk (the poor) and those with out a voice that have extremely limited to no resources.  (Many of our clients do not even know about the limited free community resources.) This will relegate them to be pushed further out of sight and relegate them to the outskirts of society and our communities. This feels like a direct affront to the poor and to the small business owners that will incur higher costs. Yes, some agencies need to be audited for income while providing no benefits for employees, and for fraud, and for a host of things that do not meet the regulations. However it is my experience that the majority of small agencies want to be in compliance and are working hard to deliver the best of services in the most cost efficient manner and provide a living wage and benefits or working toward such.