The Virginia Association of Community-Based Providers (VACBP) represents private-sector providers of behavioral health, substance use disorder and ABA services throughout the Commonwealth of Virginia, and submits these comments on behalf of our members.

Page 27-28, Community Stabilization – Additional criteria requirements

Proposed language:

“iii. Individuals meeting either criteria i. or criteria ii. above must also meet the following additional criteria:

(a) The service that the individual needs and is recommended by a professional listed in item i. above or a professional coordinating the discharge plan from services listed in item ii. above is not currently available for immediate access;

(b) There is evidence that if immediate access to the intended referral service is not available, the individual is likely to go into crisis or experience a dangerous decompensation in functioning and thus community stabilization is necessary in order to maximize the chances of a successful transition to the intended service;

(c) A clinically appropriate and specific behavioral health service provider referral(s) has been identified and a plan for the timeline of transition from Community Stabilization to that provider has been established and documented. If the timeline for this transition exceeds 2 weeks, the Community Stabilization provider has documented communications with additional, specific service providers to support additional service options or potentially faster access to the recommended service type.”

Concern: Criteria iii. (b) and (c) achieve the same objective.

Recommendation: Simplify the criteria by removing criteria iii., (a) “The service that the individual needs and is recommended by a professional listed in item i. above or a professional coordinating the discharge plan from services listed in item ii. above is not currently available for immediate access.”