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
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4/11/13  3:47 pm
Commenter: Michael L. Keohane

Proposed Changes for Mental Health Supports
 

Like many other providers across the state, Highlands CSB is concerned about the proposals that are being considered for implementation.

The Highlands CSB manages services for over 805 consumers and provides Mental Health Support Services for 100 individuals with serious mental illness. This is a population of individuals whose illnesses are so severe that they have lost much of their ability to navigate in the ways most people are able to care for themselves and function in their communities.  MHSS is one of the most vital services that assist these consumers to remain in their communities and to avoid repeated emergency room visits and hospitalizations or continuous hospitalization (or incarceration). 

As a CSB, our organization serves those individuals who are most ill and most in need of these supports along with other wrap-around services. MHSS and other supports are the very services that stabilize consumers' housing situations, one of the most critical core needs of consumers.  If the proposed unit of service/rate change for MHSS is adopted, it will compromise this CSB ability to provide this service for 100 consumers.  Without MHSS as part of the services plan, other wrap-around services will not be effective in maintaining their community tenure and these consumers will default to more restrictive and expensive levels of care, not necessarily in the fee for service system, but rather in managed care inpatient use or state hospital use. 

The Highlands CSB opposes this unit/rate change in MHSS.  While the MHSS claims will decrease if such unit/rates are implemented, the cost in alternative and less desirable services will be evident.  Even more, the progress that our 100 consumers have made will deteriorate because there is no other service that can substitute except a more intensive service, which goes against the best practice of least-restrictive service.

Thank you

CommentID: 28011