Families of people with mental illness who receive Medicaid-funded services and service recipients understand that revisions must sometimes be made to services in order to ensure that quality and effectiveness is maintained. Publicly funded services should be used in a way that is effective, both for the person receiving the service and for the system as a whole. We know firsthand how important it is for those who need services to be able to get them, and that there are many people who don’t get the services they need, often because there are not enough precious resources to go around and because the system can be complex, confusing, and difficult to navigate. Accountability is critical so that providers are held to high standards and service recipients and their families can feel confident that the services being rendered are beneficial.

As a general comment, Virginia should adopt practice models for Medicaid state plan options including intensive in-home, therapeutic day treatment, mental health support services, and crisis services to determine the types of interventions and outcomes that are needed and that should be expected from each type of treatment, and so that families and service recipients know what to expect of the service and the provider. Having defined practice models and outcome measurements will help to ensure that services are the most effective possible.

Specific comments about the proposed regulations include:

Prescreener qualifications: The BHSA has a financial interest in keeping individuals out of the hospital. There appears to be a conflict of interest with allowing the prescreener to be an employee of the BHSA. We ask that this be reviewed.

In several places throughout the proposed regulations, the term care coordination is added and case management is deleted. In other places these terms are used simultaneously (“care coordinator/case manager”). Please clarify what these changes mean.

Intensive community treatment: Removing case management from Intensive Community Treatment is troubling. Licensure through DBHDS for this service is based on a nationally-recognized PACT model. Removing case management as a required element of ICT conflicts with this nationally-recognized model. How will this change impact the service, licensure, billing, and service recipients?

The ADL definition should include budgeting and money management, medication management, budgeting, and meal planning/shopping. These are often typical activities and skills needed by individuals experiencing or recovering from chronic, serious mental illness in order to navigate one’s community and live successfully in it, and achieve a more typical, normal day-to-day life.

Regarding the proposed marketing rules, we are pleased to see these and support them.