The proposed changes to MHSS pose a detrimental effect on current and future clients.

MHSS was originally developed to help individuals with SMI remain safe and independent in the community. The regulation changes to cap daily reimbursement while increasing the number of units throughout the authorization period indicates a push to a more frequent service. This change will likely cause more harm than good by restricting additional support for appointments when needed while simultaneously increasing dependence on the provider. This change stands to redefine MHSS in opposition to its original intent: independence.

MHSS serves to educate individuals about independent living skills, including developing an effective way to communicate with their providers. Many of the clients struggle to adequately communicate their needs to providers throughout appointments without appropriate modeling and support, as well as repeated preparations prior to appointments. Without the presence of additional support, these individuals receive inadequate care due to cancellation of appointments or inaccurate reporting/comprehension. Very few clients in this population have a strong network of supports and will likely be unable to use natural supports to aid in understanding or preparing for medical/psychiatric appointments. The reimbursement limit serves to discourage MHSS clinicians from attending these appointments due to being inadequately reimbursed for their time and services.

With the majority of the population learning from visual and kinesthetic strategies, merely talking about an event prior to its occurrence will not suffice to prepare someone to complete the action independently. Modeling has proven to be a more successful approach when working with people with SMI. The daily unit cap is a disservice to those in need of skills training, particularly related to medical providers. Even from a financial perspective, this reimbursement cap will have long-term problems. It is far less expensive to have an individual provide skills-training on how to communicate with their providers and ask questions to clarify than it is to pay for continued mismanaged medical and psychiatric disorders (prescriptions, hospitalizations, doctor visits, etc.).

The unit cap will likely isolate and negatively impact individuals located in rural areas, particularly Southwest Virginia, where a limited number of providers and specialists are located. Southwestern Virginia is currently home to a higher proportion of people in need of services (mental health, substance abuse, medical, etc.) than the remainder of the state. This vast geographical area is home to only a handful of specialists and overflowing waitlists for providers across this area. The nearest specialist can be across state lines or up to 4 hours away. Compound this with the unreliable Medicaid transportation services and no public transportation in this area, and this region is facing regulation-based discrimination and poverty. This area is already struggling with a high prevalence of SMI and substance abuse, so limiting the unit reimbursement to 2 units per day will likely result in further deterioration of this region. This change serves to have no effect on higher populated areas and reduce care for people in more rural communities. This is an unjust move to further separate those in need from appropriate care.

Additionally, these restrictions will further push providers out of Southwestern Virginia, continuing this vicious cycle of poverty and inadequate care. The human capital flight epidemic will continue in this area and the gap between available providers and those in need will widen even further.