As a provider of community mental health services and the President of the Association for Community Based Services, I have concerns about proposed regulation changes pertaining to Intensive In-Home Services. I wholeheartedly agree with and support the arguments made by my colleague Mr. Slabaugh.

12VAC30-50-130 (Draft Regulations)

Re: the addition of language "Care coordination" and elimination of “case management activities”

Comments/Recommendations:  This change not only restricts activities allowed by the In Home worker which are essential to the well being of the family, but excludes non medical involved parties such as school and courts.  

Case management has long been a part of Intensive In Home as the families we serve have very complex needs that directly affect the emotional stability of the identified client.  

Furthermore, the CSB's are currently the only providers allowed to bill for case management so, to exclude case management from Intensive In Home would require the family to seek out the CSB for Case Management.  The CSB's do not have the capacity to handle the volume.  Therefore, case management should be opended up to private providers.

12VAC30-50-226 (Draft Regulations)

Re: addition of language “The documentation shall describe how the alternative community service location supports the identified clinical needs of the individual and describe how it facilitates the implementation of the ISP” and removal of the language “In some circumstances, such as lack of privacy or unsafe conditions, services may be provided in the community instead of the home”.

Comments/Recommendations:

Here I agree with Mr. Slabaugh:  "The new language creates an unnecessary and subjective burden by requiring documentation of a correlation that may not exist". 

12VAC30-60-61 (Draft Regulations)

Re: addition of the language “documented” in the follow policy:

b. Exhibit such inappropriate behavior that documented, repeated interventions by the mental health, social services or judicial system are or have been necessary.

Comments/Recommendations:

The addition of this language will create an unnecessary barrier to services.  This is clearly an attempt to prevent needy families from obtaining a service that, when done well, will prevent the familiy from seeking more costly services such as hospitalization.

I wil be the first to agree that Intensive In Home services as they stand are far from ideal. However, the proposed changes seek only to limit access and water down the service as opposed to strenghtening it.  I propose introducing interpretive guidelines to the DBHDS regluations (as has often been discussed). And thoroghly examining the utilization rates of case managemnt by the CSB's.

As ususal, there seems to be no other logical or data driven information to support the changes being proposed.  This seems simply an attempt to reduce utilization thus punishing the families who desperately need help.