According to the memo that was sent out on 10/31/13 from DMAS these changes were to “ensure appropriate utilization and cost efficiency for Medicaid or FAMIS reimbursed services, and will clarify the rehabilitative focus of Mental Health Skill-Building Services.”

“Ensure appropriate utilization and cost efficiency”- First of all, this could have been done already if the regulations that have been in place were enforced a long time ago and across the board.  I know of many providers that have never been audited and they are the ones providing services to clients unethically, maxing out hours and units on them and in some cases committing Medicaid fraud.  Why aren’t these providers being regulated or shut down??  Who does this hurt when regulations are not enforced like they should be?  The client!!  It is unfair to clients to receive services that are anything less than what MHSS was designed to be.  Lawmakers you have not fixed this problem and it will not be cost effective for you.  The new/stricter criteria and requirements of documentation of prior psychiatric history BEFORE services begin will force these clients out of services or from receiving services.  This at-risk population will drastically be effected and hospitalizations, incarcerations, and homelessness will increase.  Providers who are unethical and have been cheating the system for their own financial gains will continue to do so and possibly even take on the clients that quality providers will let go as they will abide by the new regulations. These are not cost saving measures!!

“Clarify the rehabilitative focus of Mental Health Skills-Building Services”- The focus of MHSS has always been to provide support and assistance of mental health needs while providing active skills training to clients.  We have to be able to address the mental health side of things in order to address the skills training.  From the SRA denials that I have seen from Magellan we are now taking away the supporting of mental health issues and now focusing purely on skills training.  Assisting clients with coping skills, anger management or mental health issues is considered “talk therapy” according to the denials.  We are now to provide mechanical, action-oriented skills training and what? Refer clients to counseling?  I am an LPC and I believe that MHSS is a very valuable service to clients and the level of care that is provided by MHSS providers to clients is much greater than an outpatient counselor can provide as we only get to see them for one hour at a time in our office.  MHSS providers get to work with clients in their environment and have the ability to see firsthand how their mental health affects their daily living and work with them to resolve any issues.  This is why MHSS works and is a valuable program to the community! 

In summary, the reason for these changes as I quoted from the memo above would have not needed to occur IF regulations were enforced.  Providers would have been held to the regulations which in turn would save money and the focus of MHSS would have not needed clarifying.  All providers need accountability!  Clients deserve quality/ethical services!  Do not punish them with these changes!