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  8:21 pm
Commenter: Todd Stanley, MS, LPC, NCC

Hurting VA’s Most Vulnerable
 

As a licensed mental health professional in VA, I am deeply concerned regarding emergency regulations pertaining to Mental Health Support Services, now Mental Health Skill-building Services (MHSS), that took effect on 12/1/13.

My concern is for the thousands of low income individuals in VA with severe mental illness who will no longer qualify for services due to misguided attempts to curtail spending. Many individuals with severe and chronic mental illnesses have been able to avoid the need for intensive services (psychiatric hospitalization, residential crisis stabilization, ICT, PACT, RTC, or TDO) thanks to quality community based services, such as MHSS, that have allowed them to remain independent in their homes and communities. These individuals will now be denied access to MHSS, thanks to more restrictive eligibility criteria, and will likely experience relapse without further reinforcement of skills.

Consider this scenario: You visit your doctor with severe and chronic chest pain. Your pain is causing impairment in major life functioning and has dramatically decreased your quality of life. In addition, your doctor warns you are at risk for heart attack or death. Your doctor then prescribes medication to treat your pain. After beginning the medication your pain reduces to the point that you are able to enjoy life again and your risk for heart attack or death has been drastically reduced. Several months later, your doctor receives a call from your insurance company stating, that due to overrunning costs, he can no longer prescribe you the medication because you have never experienced a hospitalization. You have not yet proven your illness is severe enough to warrant the treatment. After several weeks with no medication, your chest pain resumes.

Several months later, you experience a heart attack and die.

Too dramatic? I don’t think so.

Restricting access to MHSS will in fact be a life or death situation for some. For others, it will mean a return to severe isolation, avoidance, and increased suffering. MHSS currently provides consumers with the skills training, encouragement, modeling, prompting, and support they need to combat the symptoms of severe mental illness. Please do not punish individuals for not yet proving their mental illness is severe enough to warrant specialized care.

MHSS currently serves VA’s most vulnerable population, i.e. individuals experiencing both poverty and mental illness. I want to speak up loudly for this group because, due to their illness or circumstance, they may lack the skills or ability to do so for themselves.

As an alternative to more restrictive eligibility criteria, I suggest DMAS focus their efforts on ensuring greater adherence to current regulations. I believe this will create a “win-win” scenario for VA, i.e. costs will decline without denying individuals a service they need.

CommentID: 29461