I would like to hope that these comments will make a difference.  I would like to think that this input will be read and incorporated into the decision as to whether or not these regulations will be passed.  I would like to think that the individuals in our state who will lose services because of the changes, will be ok.  Right now, I am just not sure.

As I sit here to comment, I am receiving emails and phone calls from offices that have already tried to enter clients into the Pre/re-authorization system under the regulation changes that are listed here as emergency regulations, but really went mostly into effect 2 days ago.  All of the authorizations have been denied.  In spite of assurances from regulatory agencies that they do not want clients to lose services, they are rejecting the very clients whose lives we touch every day throuhg MHSS.  In one case the client meets every eligbility criteria, but was not approved because we didn't list enough "hands-on" skills traiing in the narrative of the request.  We are being allowed to re-write the request, and hopefully we will get it right this time.  This is a client that struggles with suicidal thoughts on a consistent basis.  We have been told that issues like that need to be handled by a counselor, not by skills training such as coping skills.  In another case, the person meets every criteria and needs the service, but we cannot get the documentation of prior mental health services, so she is denied.  Again, a client with a history of sucidal ideations and one who deals with suicidal thoughts consistently.

There are many public and private MHSS providers who are ethical and try their best to provide good, therapeutic services to clients who have finally found a service that can meet them where they are and provide what they need to live independently in the community.  These providers have quality assurance measures in place, check for Medicaid fraud and do not tolerate unethical, fraudulant behavior from their staff.  Unforunately, there a many providers who not only do not have these measures in place, they actively participate in and encourage fraudulant and/or unethical behavior.  These new regulations will only benefit those providers.  Ethical providers will truthfully complete requests for authorization and dishcarge clients who do not meet new criteria.  Other providers are waiting in the wings to pick up those clients, take them out to a game or out to eat and bill the maximum units allowed for the client each week.  Spending in the state will increase again and MHSS will be cut completely.

In order to cut spending in this program, any regulation must be enforced.  If the previous regulations had been enforced, spending would not be out of control for MHSS.  Enforced regulations would also mean better quality services for the mentally population in our state.

The title of my comment is "Can we make a difference".  The truth is, many of us are making a difference every single day in the lives of the mentally ill in Virginia.  We are saving lives of those who suffer from the most severe symptoms of mental illness.  We are fighting the stigma of mental illness and fighting for the rights of those who suffer from it.  We are fighting those agencies who do not provide ethical services.  I hope we will continue to be able to truly make a difference for our clients.