We respectfully request that Virginia Department of Medical Assistance Services reconsider the proposed changes to face-to-face service requirements and administrative timelines for case management services.

The increase from one face-to-face contact every 90 days to two required visits per quarter, along with specifying location such as community settings, presents significant challenges for the populations we serve. DMAS case management providers often work with individuals who have complex behavioral health needs, trauma histories, and heightened concerns about privacy and stigma.

Many individuals express clear preferences regarding how and where they engage in services. Some may only be willing to meet in limited settings, while others may decline home visits or feel uncomfortable being seen with staff in public environments such as parks, workplaces, or other community locations. A more prescriptive approach to visit frequency and location may unintentionally create barriers to engagement rather than improve service delivery.

Additionally, further clarification is needed regarding how refusals will be addressed. If an individual declines a required office or community-based visit, how will this impact service eligibility and provider compliance? There is concern that rigid requirements could result in unintended service disruptions for individuals who are otherwise actively engaged in care.

We also request reconsideration of the requirement to submit new case management registrations within one business day. While we understand the importance of timely authorization, this timeframe may not be operationally feasible in all circumstances, particularly when staff responsible for submissions are unavailable due to leave or other coverage limitations.

Compounding this challenge is the lack of a standardized registration process across managed care organizations. Providers must navigate multiple systems, including portal-based submissions, registration forms, then we have gold card , depending on the payer. These inconsistencies create administrative burden and increase the risk of delays despite providers’ best efforts to remain compliant.

We encourage DMAS to consider more flexible, person-centered guidelines that allow providers to meet individuals where they are, both clinically and practically. Flexibility in visit frequency, location, and administrative timelines would better support engagement, continuity of care, and overall service effectiveness while still aligning with DMAS’s goals for quality and accountability.