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  1:23 pm
Commenter: Mike Abajace, Hall Community Services

repeal, reevluate, revise
 

While it is evident that we need  to ensure appropriate use of resources, taking services away from some of the most disadvantaged members of our community is certainly not a well thought out approach. Those who have made and will enforce the ‘emergency regulations’ may never observe the consequences of their decisions first hand, rest assured, that the impact will be great in both number and severity.  Moreover, while it is quite obvious that this is being done in order to reduce spending, it will have quite the opposite effect. I am very confident that many of the individuals that will no longer receive services due to the new regulations will be psychiatrically hospitalized, costing significantly more in the long run.

While MHSS should be a service that is delivered only to severely mentally ill individuals, setting admission criteria to exclude individuals who have never been psychiatrically hospitalized or on psychotropic medications is far from the best protocol.  Many clients that I have worked with who will no longer meet criteria under the new regulations were significantly more appropriate, and more engaged in services than those who will meet the new admission criteria.

When KePro was introduced as an entity to begin screening for admission/continuation criteria, I welcomed this change. We all know that misuse and abuse of resources happens across the board. When there is little oversight, many agencies and individuals alike will take all that they can get away with. Having a third party to determine eligibility is an excellent way to reduce instances of inappropriate use of the system. 

Instead of creating these new (ill advised) regulations that will end services for thousands of Virginia residents with severe mental illness, why not enforce current regulations and policies? If a reduction of cost is top priority, then conduct effective audits, employ individuals on a regional level to review questionable cases and actually meet with individuals who are borderline regarding meeting admission criteria. But please do not shut the doors to some of the most vulnerable members of our community.

If the powers that be at DMAS were to take the time to meet with the individuals receiving services, the caseworkers, and the agency management representatives, I am certain that together we could devise a solution that would not result in an increase in hospitalizations, homelessness, and incarceration for individuals with severe and persistent mental illness. The emergency regulations need to be repealed, and funding/ budgeting for MHSS must be handled in a more productive, client centered fashion.

CommentID: 29590