I appreciate the opportunity to comment on the proposed changes to the mental health services program.

As a provider serving a large rural area, we consistently face significant challenges recruiting qualified individuals to deliver quality behavioral health services.  This has been compounded when we begin a service and an entire program based on an initial set of criteria, including staffing credentials, and then this changes at some point in the future.  While there has been consideration given to "grandfathering" staff for which we are grateful, staff attritioning out of our system need to be replaced under the new credentialing criteria.  What was difficult initially is now even more so.

Restricting clinical experience to individuals who have performed their functions in a full time capacity and eliminating the clinical experience of those who perhaps out of necessity gained the same clinical experience in a part time capacity appears to be discriminatory and narrowly focused.  Moreover, this will further reduce the professional cadre of staff available for hire at a time when there is an increased demand for services.

We respectfully request that the clinical experience apply to that experience gained in a part time basis and that "grandfathering" and approved variances should continue to be allowed and remain in effect.

We understand the need to provide thorough and comprehensive documentation; however, we have concerns that the proposed regulations appear to indicate that there is no distinction between significant errors that are clearly out of compliance with the regulations and those of a more minor category.  Both errors will result in a payback.  We respectfully request that distinction between those significant and minor errors be considered.

We do not agree with expanding the certified prescreener designation to other entities as proposed.  The Code of Virginia specifically limits CSB/BHA clinicians as the certified prescreeners.

We do not support the definition of activities of daily living as it appears in the proposed regulation.  We believe it reflects the need of some individuals with disabilities but should be broadened in order to more acurately address the need of individuals dealing with mental health issues.

Additionally, we support the comments provided by the VACSB.