Regulation changes pertaining to Intensive In Home services

As an employee of a community mental health services organization and having worked in direct service myself, I have concerns about the proposed regulation changes pertaining to Intensive In-Home Services and how this will impact the work organizations are able to do in and for their communities. I wholeheartedly agree with and support the arguments made by those in my field who have commeted before me.

12VAC30-50-130 (Draft Regulations)

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

Comments/Recommendations:  The change, while seemingly insignificant, would inhibit the work that the In-Home worker is allowed to perform. 

Case management has long been a part of Intensive In Home Services as the families our organizations serve have extremely complex needs that often overlap and can directly affect the emotional, mental and physical stability of the participant. The ability to provide comprehensive Case Management Services (specific actions that lead providing the best care and improvements in quality of life for each inivdiual) is essential to the work that In-Home Services provide. Limiting it to "Care Coordination" will inhibit the specfic tasks these workers are allowed to perform, thus limiting their ability to provide the best services for their clients.     

In additon, the CSB's are currently the only entity allowed to bill for case management services. If this service were excluded from Intensive In Home Services, it would create a burden of work for the CSB's and our fear is that the CBS's will not be able to meet this new influx of clients thereby allowing many clients to fall through the crack. This would excerabate many of their mental, emotional and phyiscal states and cause further issues for them as indivdiuals but also for the state. 

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:

Here I agree with Ms. Cheeks: "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...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."