To whom it may concern,

I would like to recommend organizing an advisory/work group/commission etc. comprised of those knowledgeable/experienced in EBP services to assist with the EBP aspect of this proposal. EBP services in Virginia have been a niche service, and this design outlines a significant market shift for consumers as well as providers. Over the last several years I've spent a lot of time learning certain EBP models and becoming an advocate for these types of empirical evidenced based services that historically produce better patient outcomes and control cost. However, I do have concerns with several key areas; to include scalability and sustainability for providers (which impacts patient access to care), provider startup capital requirements and EBP model requirements being able to fully align with Federal and State regulatory requirements under CMS, DMAS and DBHDS. I also have concerns with our human capital resources as it relates to how our workforce in Virginia has shifted since Phase 1 of redesign and Covid, and if there needs to be clinical and regulatory adjustments to better reflect our current workforce market. These programs can be labor intensive.

-This group for example would assist with understanding what a new provider financial profile should consist of and if current requirements for new provider applicants are a realistic barometer based on the carrying cost associated with EBP service models. Or if EBP companies can adjust model requirements to assist with lowering cost for new provider applicants in year 1. Also evaluate areas of adjustments for agencies/companies beyond year 1. 

-This group for example would evaluate current Federal and State regulatory requirements and work to see where adjustments can be made to fully align all regulations and EBP clinical models. Also work to align EBP model language with regulatory language or vice versa. This may result in developing completely different provider manuals (all chapters) and or how they are formatted (structurally, terminology/language, utilization etc.) for EBP services.

-This group for example would assist with developing a strategic EBP Statewide development plan based on market analysis and business impact studies (to include small businesses) and subsequent transition plans designed to insure long term sustainability and growth of EBP services in Virginia. This would include evaluating all existing statewide EBP data/outcomes.