In addition to the comments submitted, please note that the previous changes to the MHSS program have already limited the access to MHSS services for a number of individuals who were using them to remain stable within the community.  With the move to more community based treatment for individuals who experience mental health issues and the utilization of hospital treatment as an acute care model, there is need for more, not less, access to services that are recovery based and community based..

The points outlined in the prior comment (prepared by a colleague) were spot on about the effect the proposed changes would have on the availability of services to support those individuals living in the communities in VA with a diagnosis of mental illness.  To remove those and make access much more difficult would put them at serious risk of prolonged hospitalization at a cost much greater than the cost of MHSS services, and in direct conflict with the philosophy of person-centered care and least restrictive care which has been adopted nation wide.  The history of the struggle of those with mental health diagnoses has led all professionals to adopt a recovery model of care, which is based in the belief that the individual is the expert in what services they need and creates a partnership between the provider and the individual served to best allow the individual to recover from their illness and move on to a more productive, independent life.

The changes to the MHSS and crisis stabilization services remove the individual from that equation and place arbitrary limits and approvals to the amount and types of care they need.  These decisions are made by a professional who has never seen the individual.  That professional holds within their hands the access to needed, possibly llife saving services, which they make a decision about solely by what they see on a computer screen.  The MCO is charged with saving money, not providing the best possible outcome for the individual.

In addition, there is an inherent contradiction in this proposal.  Where DMAS has stated that MHSS services are less intensive and can be provided by QPPMH level staff, they are increasing the level of staff who will actually write a treatment plan for the service.  The ISP is meant to be the plan the individual develops for their treatment. The consumer movement has adopted as their motto "Nothing about me, Without me". However, the cost (unreimbursed) to the agency to move to an ISP having to be written by an LMHP is exponentially higher.  The rate for MHSS services is based upon the service being performed by a QPPMH staff, not a much more expensive LMHP.  Agencies will be forced to make this work, and will have to choose to lose revenue or not provide the service.  Agencies who provide the service will necessarily have to limit the total amount of time that the LMHP has to spend with the individual in the writing of the ISP due to lack of reimbursement and the consumers input will suffer accordingly.

Being a provider who has worked in two other states and for an agency that provides service in 8 states, this standard of an ISP being written by an LMHP is far above the accepted standard I have experienced, or have knowledge of.  Professionally, the standard is for the LMHP to review and sign off on the ISP, but the ISP is written by the non-licensed staff in conjunction with the individual served.  VA is the only state that I am aware of that would require a licensed professional to spend their time actually developing and writing the plan.

I implore you to consider the text in my prior comment and to think about those individuals who will suffer due to the lack of the community resources they need to remain in their community of choice.  I also implore you to take a closer look as to why the most severe cost savings efforts so often target the mentally ill population.  These changes will make services less effective and less available in a time when average people are struggling to understand why the mental health sysytem is ineffective in preventing tragedies.

 An overall vision for a system of care needs to be developed and implemented instead of constant changes to a system which inevitably break down the system of care. Cost savings on the back of the mentally ill are short sighted and create even more social injustice for those already suffering from a mental health disorder.