Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
chapter
Amount, Duration, and Scope of Medical and Remedial Care and Services [12 VAC 30 ‑ 50]
Action 2011 Mental Health Services Program Changes for Appropriate Utilization & Provider Qualifications
Stage Proposed
Comment Period Ended on 4/12/2013
spacer
Previous Comment     Next Comment     Back to List of Comments
3/13/13  1:25 pm
Commenter: Anita Mitchem, Behavioral Health Quality Management Consulting

proposed changes to mental health supports
 

I have multiple concerns regarding the proposed changes to mental health support services:

1. The proposed name change to "skill building" service is suggestive of a developmental disability type of service. While the primary focus of mental health supports is to assist individuals in development of daily living and other skills, the idea of a pure focus on training is indicative of a lack of understanding of the complexity of dealing with individuals who have a serious mental illness.

2. While sessions of longer than 5 hours should not be routine there are rare occasions when this may be appropriate and should be acceptable when accompanied by detailed documentation.

3. The requirement for a prescription for anti-psychotic or other psychiatric medication within the last 12 months will prohibit admission to this service for many who need it most. Due to lack of resources, geography, insight, and the illness itself, it is extremely common for this population to not see a Dr. or other medical professional for many years.  The need to help this population access medical/psychiatric service and understand the need for medications seems to me to be one of the primary functions of this service.  

4.  Licensed Mental Health Professional Eligible is not used in the language regarding who can do assessments.  If LMHP-E staff can no longer do assessments, this will dramatically slow down the ability to get individuals into much needed services. In the more rural areas of the state there are a limited number of LMHP's which will greatly inhibit access to service.

5. The limitations being placed on admission for anxiety disorders seems to be contradictory to the requirement of individualized assessment and service planning.  Admission should be based on need and functioning not solely diagnosis. PSTD and many other anxiety disorders are extremely debilitating and individuals with these disorders frequently require vast amounts of support.

The individuals who receive mental health support services are frequently some of the neediest and most ignored of all populations. Virginia offers very limited services to this population and in an effort to save a nickel ends up spending dollars on jails, prisons, emergency room visits and hospitalizations.  When implemented correctly, mental health supports actually saves tax dollars, makes our communities safer and provides individuals with serious mental illness an actual path they can follow on the road to recovery.

Thank you for your time.

CommentID: 26553