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 Final
Comment Period Ended on 7/27/2016
spacer
Previous Comment     Next Comment     Back to List of Comments
7/25/16  10:17 am
Commenter: Misty Disharoon

MHSS daily unit cap changes
 

By providing a 2-unit cap daily per person, DMAS recipients will not always receive appropriate care in regards to needs.  Due to limited availability of specialists, medical and mental health, in our rural area, clients may need to travel to outlying areas to receive such care.  Medicaid transportation is available for clients to access such providers; however, due to anxiety, limited ability to self-advocate, difficulty with management of anger and other emotions, and difficulty in remembering and effectively communicating questions and concerns with providers, MHSS providers are often needed to provide real-time training on how to effectively access and utilize such specialist services to ensure that needs are met.  Upon completion of such appointments, medications are often needed to be obtained and this further extends the time needed to be utilized during such sessions. 

In assisting clients in accessing needed resources, the 2-unit daily cap may be detrimental to the clients' mental health as they may be facing eviction, legal interventions, and/or disruption of services (such as electricity) and require assistance in accessing such resources to prevent such crises from occurring.  Due to many such resources being on a first come, first served basis, clients and clinicians may be required to participate in lengthy wait times to receive such assistance in accessing resources. 

If a client is in need of emergency care, the daily cap could decrease access to such care as many clients will not access such services without the assistance of a clinician.  Due to limited emergency services in rural areas, there is frequently an extensive wait time to be seen when accessing such services and this could place the clinician at risk of exceeding the unit cap.  However, if a clinician is to leave a client waiting for services due to daily unit cap, there is risk that the client may leave the facility and not receive the needed emergency services that they were seeking.

By capping the units in a manner that could decrease the quality of services provided to clients, DMAS is removing the person-centered focus of care and services may be viewed as neglectful and border violation of client rights as their needs may not be fully addressed due to MHSS need to limit services to ensure compliance with DMAS regulations. 

Due to the daily cap, clinicians who work in excess of three hours may not receive adequate compensation as financial reimbursement will not be provided by DMAS, the quality of MHSS clinicians may decrease throughout the field as a whole.  Clinicians enter the workforce to ensure ability to provide for their families and if pay structure is interfered with, clinicians may enter other fields and create a decrease in available MHSS providers, which further decreases the ability to meet the needs of clients seeking MHSS.

CommentID: 50660