I wanted to post a public comment on these proposed changes, specifically those listed in Appendix G. As a provider who has over 15 years of experience in the mental health field in Virginia I find it very disappointing to see how many additional barriers these new policies are adding to an already extremely difficult duty of providing quality services to individuals in crisis within our community.
Im not sure if these proposed changes are attempting to eliminate the ongoing waste of medicaid funding for community based services, but I will say that not all companies are abusing the system and it feels like a direct attack on all private providers to add even more barriers to service delivery for our clients.
This particular policy shows one of many extremely difficult aspects we face as a provider:
"If an individual has received Community Stabilization services at any time in the previous 30 calendar days with the same or a different provider, an initial service authorization is required. A registration is not permitted."
For us to even know if a client has recently been provided Community Stabilization is almost impossible while assisting those in legitimate crisis because the Crisis Call Center, MCO's, and other busy private providers are usually unable to provide this information to us within a timely manner. There is no unified source of information that can be accessed by our staff to obtain this information.
The extreme reduction of units for initial registrations also is burdensome and will only add to the frustration of hiring quality staff to provide a service that is much needed when they are unable to get anywhere near full time work with a maximum of 12 hours of service allowed for a client over a 3 day period. If we are expected to simply submit a continued stay request I genuinely don't think that it's understood the high level of stress, frustration, and MCO correspondence delays that come with continued stay attempts.
I strongly suggest that sincere re-evaluation of these major changes take place to prevent a collapse of all the hard work that was done to redesign the behavioral health services in the state of Virginia. While I understand that abuse of these services is very widespread and they cost the state a lot of money, not all providers are abusive and it really is disappointing to those of us who genuinely care to see even more changes/restrictions/barriers to quality service delivery. Losing quality providers who are educated and motivated to help should not be the goal of DMAS. It seems by these policies that pushing providers to the brink of extreme mental fatigue and high staff turnover is the end goal. This is really unfortunate for all quality private providers who are the backbone of community mental health services across the state.