The Child and Family Council of the Virginia Association of Community Services Boards are concerned about recommended changes to MHSS that would unduly limit access for youth.  Young people, especially in the ages with the most restrictive criteria (ages 18 to 21) need the reliable and consistent support and training that this service can provide. This is often the age that families become aware of changes in their child and seek professional help.  This service allows for the hands-on professional relationship that can be offered to help a young person come to an understanding of serious mental illness, help them make choices about treatment, provide encouragement and hope when this hurdle seems insurmountable and to be the trusted, steadfast provider when a crisis looms. This consistency can certainly be in the service of reducing costs (i.e. prevent hospitalization) but more importantly engages the individual in need to participate actively in their own recovery.

To require youth ages 18 to 21 to be in an independent living situation is to be woefully unaware of the nature of serious mental illness and the dependency it often creates in the young person.  It is the fortunate individual whose family continues to provide a measure of support, such as housing, while they try to become more self-sufficient.  To require independent living for individuals ages 18 -21 but not for those over 21 appears to be age discrimination.

The requirement for a prescription for major psychotropic medication is another area of concern.  While it is true that medication can be helpful, and sometimes is necessary, for recovery, not all individuals enthusiastically embrace medication as a first line of treatment.  Psychotropic medication can carry serious side-effects. It is understandable that many would prefer to try other less restrictive, alternative methods to improve their psychological functioning. Rather than require the physician to document that medication is medically contraindicated, we ask that you consider the eligibility criteria to be changed to “under a physician’s active care and review” of the individual’s treatment.  This would allow for the development of the cooperative and collaborative relationship between the individual and his/her doctor that will be needed for long-term recovery.

Finally, while we support the idea of a specific service plan that delineates the typical frequency and length of service to be provided, we ask that you make provisions to allow for “periodic supports” to be made available for times of crisis. To define MHSS as not a crisis service and thereby force an individual in the grip of a crisis to turn to an unknown provider rather than the provider they have come to know and trust cannot be seen as best practice.  Often these crisis situations can be addressed and managed by helping the individual access informal community supports without resorting to formal emergency services and TDO evaluations (which can be extremely stressful to all involved) and obtain more durable results.

We ask for reconsideration to these criteria in the permanent regulatory process with exceptions allowable now.