We identified two clients with serious mental illness Schizoaffective and Schizophrenia who have declined medication for over 12 months.  Both live in our community and can have involvement with CIT and ECO.  MHSS and MH CM continue to be provided to both clients to work closely with them to continue to engage them in services and address any health or mental health related issues that arise.  In the new regulations that require one to be prescribed a psychotropic medication in the past 12 months these clients would not meet that standard and could not receive the service.  While it is not ideal that they are currently declining psychiatric medications it can be the nature of the illness at times that medications are stopped for longer than 12 months.  With the new regulations the client could not receive MHSS and be at much greater risk for health and safety concerns as a result.  Not the intended consequence of the regulation.

A second concern was the discontinuation of the units for over 5 hours of services.  Many of our clients require travel to regional Hospitals or specialists for various medical care (UVA, VA Center in Salem).  Adding the fact that we are in a rural area it is not uncommon for our staff in MHSS to have at least one case per week that takes this type of time with a client to assure they get to their specialist and during the visit are aware of any changes to their treatment plans as well as returning safely to their home at the end of the day.  We would recommend the option continue a unit billing with the 7 hours and in order to better manage the number of such units it is recommended that the provider as part of the Kepro Authorization justify a limited number of the 7 hour units per client per authorization period.  This would allow some control of the use of the unit of billing based on the needs of the individual client.  NOTE: This is not the case management process of "linking" to medical services.  This is being with the client throughout the entire waiting (with their anxiety) for the doctor and with the client during the appointment.