Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Amount, Duration, and Scope of Medical and Remedial Care and Services [12 VAC 30 ‑ 50]
Action Mental Health Skill-building Services
Stage Emergency/NOIRA
Comment Period Ended on 12/11/2013
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12/3/13  11:58 am
Commenter: Brad Carmichael, BS, CCTP

We Are the Voice for Our Clients
 

This current piece of legislation is disappointing to say the least.  It is unfortunate that the mental health system continues to suggest that we as mental health professionals should wait until a patient/client is already in a chronic or severe state before being cleared for treatment.  While I do recognize that some providers have abused the system, it is inappropriate to penalize everyone (including the clients) for the poor judgment of only a select group of providers.  

My first concern comes with the restrictions to obtaining assistance with housing or GED-related goals.  It is impossible to make a meaningful change with client if they are not in safe and stable housing.  Such housing cannot be attained if the the access to services is so tightly secured.  In addition, given the population that qualify for this service, achieving and maintaing appropriate housing may very well be an ongoing problem and not simply a one-time initial goal for treatment.  With regard to the GED or education-related goals, it is completely ridiculous to name such a service "skill-building" while intentionally choosing to neglect one of the most basic skills for survival: development of abstract thinking and cognitive abilities at a basic educational level.  Telling clients they cannot receive assistance with obtaining further education is punishment because it denies them the ability to receive a basic academic experience that may have been compromised by the very mental health problem that brought them to us.

My second concern is with the requirement that clients be receiving specific medication treatment.  There is a significant amount of literature suggesting that questionable benefits of psychotropic or even other mood-stabilizing prescriptions.  We cannot fully help our clients if we require them to be on a heavy dosage of medication before we even have the chance to work with them.  What about the client's right to self-determination?  If we are giving the client the right to seek services then should we not also provide them the right to seek mental health services without medication?  

This brings me to my third and final concern: the restrictions on qualifiable diagnoses.  The current restrictions send that message that clients may not be severe enough to receive services.  Who is to say that clients not given a particular diagnosis are not going to get worse?  In fact, it is very possible that a client could be at a subclinical level of a serious mental health diagnosis and be denied a service.  As a result s/he may actually develop a clinical diagnosis in the future because the system failed to help them early on.  Apparently we need to wait until they are severe enough to provide them with the help they are seeking.  This legislation completely disregards the value of client-self report and places it in the hands of medical professionals who may then feel pressured to "diagnose up" in order to receive reimbursement.  This only contributes to the dramatic rise of potentially falsified or exaggerated diagnoses appearing on permanent health records and an increase in the severity of stigma in our society.

To close, I agree that there has been abuse and insurance fraud, but the clients should not be the ones denied the right to receive services because some providers have selfishly taken advantage of the system.  If this trend in the mental health system continues, then we will see an increasingly overwhelming amount of prospective clients knocking only to find that no one is willing to unlock the door.

CommentID: 29443