The following is being entered consistent with a letter being sent by email and U.S. Mail to Ms. McClellan.

August 27, 2015

Ms. Emily McClellan

Regulatory Supervisor

Department of Medical Assistance Services

600 East Broad Street

Richmond, Virginia  23219

Dear Ms. McClellan

            Re:      Amount, Duration, & Scope of Medical and Remedial Care And

                        Services [12 VAC 30-50] -- Mental Health Skill-building Services

Dear Ms. McClellan:

I am writing on behalf of the Association of Community Based Service Providers (“ACBSP”).  Our Association is comprised of mental health providers ranging in size from mom and pop small family businesses to member companies that have several hundred employees.  Members of the Association are actively engaged in the delivery of a variety of mental health services including mental health skill-building services across the Commonwealth in both urban and rural areas.

The purpose of this communication is to oppose on behalf of the Association and our members the changes to the regulations as published in the Virginia Register on August 24, 2015.

In particular, our Association is opposed to the proposed changes that would change the mental health skill-building services (“MHSS”) to mean that a unit of service would be defined as 15 minutes.  Further in the regulations, this proposed change was anticipated to take effect on July 1, 2014.

The proposal to change the unit to 15 minutes would be detrimental and harmful to the patients that we serve.  Such a proposal does not bear any reasonable relation to the mental health illness or treatment thereof for our patients.  Finally, our Association has never supported this aspect of the proposed changes nor do we know of any provider groups who have supported it. 

We look forward to working with DMAS as always but would respectfully request that this change be deleted during the public comment period.

Should you have any questions, please do not hesitate to contact me.

Sincerely,

W. Scott Johnson

WSJ/jpr

DM #745274

cc:       Ms. Tyler S. Cox

            Ms. Molly Cheek

            Ms. Teshana Henderson

            Mr. Jonathan Coleman

            Mr. Dennis Parker

            Mr. Matt Marek