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 11, Required Activities

Proposed language:

“In addition to the ‘Requirements for All Services’ section of Chapter IV, the following required activities apply to Mobile Crisis Response:

• The provider must engage with the DBHDS crisis call center and crisis data platform prior to initiating services.”

Question/concern: Does this proposed change imply that providers would no longer be able to enroll individuals in the data platform and obtain a reference number to accompany the MCO registration process, aka self-refer?

Recommendation: Protect the current flexibility to enable self-referrals. Establishing a simple process to initiate crisis services is essential to the provider's ability to respond rapidly and effectively. Providers of crisis services have established referral networks that currently work to divert individuals from higher levels of care. Adding steps to the referral process will delay response times and weaken positive service outcomes. Regulations should work to preserve a "no wrong door” approach to delivering services.

Thank you for your consideration of this recommendation.