I do not support limiting the daily Mental Health Skill Building Services (H0046) cap to 4.99 hours, 2 units. I believe that a compromise can be made with the existing MHSS unit structure by dissolving 7+hours, 4 units but the State should strongly consider keeping the 3 unit option of providing greater than 5 hours of service. The probability and the necessity of greater than 5 hours service is very likely in rural parts of the state. Access to resources and the coordination of care can be made more timely within a Medicaid determined "Urban" rate demographic location, but this isn't the case in the "Rural" rate demographic, Virginian outlying regions. Aside from the fact that rural rates are already paid at a lower rate than Urban, the Rural demographic's timely access to resources/care exists within a larger geographical area so clearly this service will take additional time by proximity. 

I fear that adopting this regulatory proposal as it is currently written will likely dissolve the presence of Rural providers in the outlying areas of the Commonwealth leading to no access to care.