While the VACSB supports certain changes in eligibility for MHSS, we believe that the emergency regulations can have the result of excluding the very individuals who really need the service in or der to function in their communities and avoid hospital stays. The regulations can have as well the result of compromising the ability of CSBs to deliver this service for those individuals who can be diverted from hospitalization and long term placement.  We agree that the service delivery components should be skill buliding in nature because MHSS is designed to be an intensive service but it is designed to address needs of those individuals who have severe mental health needs that are persistent.  Everyindividual's recovery path is different in terms of needs and timing.  As well there are features in terms of documentation that are excessive.  One unintended result may be savings in the MHSS arena with costs in otehr arenas such as state or local hospitalization costs as well as stress on the CSB crisis systems and other human services needs within communities. 

There should be additional thought given to these regulations as the permanenet regulations are developd but, for now, DMAS sould work with providers and consumers to develop some processes for exceptions based on the needs of individuals and the service delivery provider they chose.  We stand ready to assist this process.