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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12/11/13  11:49 am
Commenter: Adrien Monti, LCSW, Hall Community Services, Inc.

Too much, too rushed, puts the mentally ill at serious risk.
 

Various elements of the abruptly enforced changes to MHSS are poorly thought out and put the individuals we serve at risk of psychiatric crisis.

Upon receiving notification that various changes would take place effective 7/1/14, I shared at a staff meeting that this would give us ample time to plan, provide training, prepare for discharge where necessary, and move forward with changes in an organized fashion.  Imagine my surprise when the implementation deadline was revised to 12/1/13, giving us almost no time to plan or prepare for massive across the board changes.

At Hall Community Services we serve three clients who we were unable to reauthorize in the first week of December alone, due to the fact that they have not had psychiatric hospitalizations or a similar intensive intervention.  All are seriously mentally ill and met previous criteria due to additional factors that are no longer being considered such as history of homelessness, involvement with the criminal justice system, history of being victimized and/or cognitive limitations.  Due to our desire to terminate in a clinically appropriate manner, we are continuing to provide at least one month of pro-bono services to these individuals.  The lack of advance notification and planning time has caused a serious hardship in this instance.  The holiday season is also a very difficult time to discuss discharge with individuals who are socially isolated and lack supportive safe relationships.  I have great concern that this will cause some to decompensate, leading to crisis situations.

That individuals now need to have received a prescription for psychotropic medication within the last twelve months is illogical.  We currently serve an individual who is diagnosed with schizophrenia and has been hospitalized multiple times.  Upon intake, she had been off all medications and had not seen a psychiatrist in over two years.  She was incapable of accessing this service without support due to her functional limitations.  Within a month of enrolling in MHSS we had assisted her in procuring a psychiatric intake and she has now been successfully medication adherent for over one year.  What happens to individuals in this situation if we are not permitted to admit them to services?

Of grave concern is the new requirement that we must obtain documentation of both a history of an intensive intervention such as hospitalization as well as documentation of a recent prescription for psychotropic medication.  I have personally requested numerous records over the years, and the return rate is poor.  The individuals we serve cannot control whether prior care providers send records at all, much less in a timely manner.  They should not be put on hold or discharged due to lack of supporting external documentation.  We also serve multiple individuals who have little recollection of prior interventions and have been unable to provide facility names or dates.  Sometimes the individuals with the greatest level of impairment and thus highest need for support are the least able to provide such information.

If changes are to be made, I would request that it be taken into consideration that the severely mentally ill population is likely to need ongoing support.  No amount of intensive training over six months or one year will render most individuals able to “graduate” and function independently with no support.  On the other hand, it would be reasonable to gradually decrease the number of hours provided over time.  Often when we admit individuals for services, they have extensive needs in areas such as housing and medical care.  Once these basic needs are situated, which can be very time consuming, clients often stabilize to the point where a maintenance level of three to five hours weekly would suffice to keep them stable in the community indefinitely. 

In the realm of services provided to those with intellectual disabilities, it is recognized that ongoing support is a necessity.  It is not expected that they will achieve a level of functioning that will enable them to move toward full independence.  I believe that for severely mentally ill individuals, the need for ongoing support is likewise always going to be present.  No one wants to see a revolving door cycle in which we cut off services altogether until individuals decompensate and are hospitalized as a result, thus enabling them to enter MHSS again for a period of time.  It would be more reasonable to provide ongoing long-term support to the most severely ill individuals who are trying to function successfully in the community, and would reduce the need for more costly and intensive interventions.

MHSS has always been an excellent service because it is readily accessible to those in need.  I have had the pleasure of witnessing individuals procure and maintain housing, comply with legal obligations, build supportive relationships with friends and family, and access needed medical and mental health treatment.  It is my hope that some of the current changes can be reversed before this service is limited and restricted to the extent that few, if any, individuals will be able to continue to reap the many potential benefits.

CommentID: 29588