Chesapeake Integrated Behavioral Healthcare---Our responses to the proposed changes are as below.

1) In reference to the following passage:

8. Mental health support skill-building services (MHSS) shall be defined as goal-directed training and supports to enable individuals to achieve and maintain community stability and independence in the most appropriate, least restrictive environment. Authorization is required for Medicaid reimbursement. Services that are rendered before the date of service authorization shall not be reimbursed. These services may be authorized up to six consecutive months as long as the individual meets the coverage criteria for this service. The service-specific provider intake, as defined at 12VAC30-50-130, shall document the individual's behavior and describe how the individual meets criteria for this service. This program These services shall provide goal-directed training in the following services areas in order to be reimbursed by Medicaid or the BHSA: training in or reinforcement of (i) functional skills and appropriate behavior related to the individual's health and safety, instrumental activities of daily living, and use of community resources; (ii) assistance with medication management; and (iii) monitoring of health, nutrition, and physical condition with goals towards self-monitoring and self-regulation of all of these activities. Providers shall be reimbursed only for training activities defined in the ISP and only where services meet the service definition, eligibility, and service provision criteria and this section. Service-specific provider intakes shall be repeated for all individuals who have received at least six months of MHSS to determine the continued need for this service.

Chesapeake Integrated Behavioral Healthcare believes completing an SSPI every six months is not practical and no other service reimbursed by DMAS has this requirement.  Additionally, completing an SSPI every six months creates an additional burden on the individual receiving the service while yielding very little, if any, additional information that could not be obtained by a review of individuals record and consultation with clinicians providing the service.

2) In reference to the following passage:

3. The LMHP, LMHP-supervisee, or LMHP-resident shall complete, sign, and date the ISP within 30 days of the admission to this service. The ISP shall include documentation of how many days per week and how many hours per week are required to carry out the goals in the ISP. The total time billed for the week shall not exceed the frequency established in the individual's ISP. The ISP shall indicate the dated signature of the LMHP, LMHP-supervisee, or LMHP-resident and the individual. The ISP shall indicate the specific training and services to be provided, the goals and objectives to be accomplished, and criteria for discharge as part of a discharge plan that includes the projected length of service. If the individual refuses to sign the ISP, this shall be noted in the individual's medical record documentation.

Chesapeake Integrated Behavioral Healthcare (CIBH) believes that QMHPs should be able to complete and sign the ISP with a review by an LMHP.  The QMHP is the clinician who is going to work directly with the individual receiving services.  The QMHP will also meets with the individual to revise the ISP when changes occur.  The LMHP assesses and provides oversight to the development of the ISP, including signing each Quarterly Review, so completing the ISP by the LMHP appears to be unnecessary.

3) The proposed changes include changes to units.  For example:

d. e. The yearly limit for mental health support skill-building services is 372 units. Only direct face-to-face contacts and services to the individual shall be reimbursable. One unit is at least one hour but less than three hours.

In the Economic Impact Analysis the following is quoted: The proposed regulations would change the unit structure to a 15 minute billing unit and decrease the number of units per day that an individual may receive the service (decreasing from seven hours to up to 5 hours allowable as a maximum of twenty 15 minute billing units per day) to ensure that the service is not over-utilized. The new unit value and new unit allowance would yield a maximum of 5 hours per day, 5 days per week for a total of 5,200 fifteen-minute units per year. The changes in the daily, weekly, and annual limits would stagger services so that they may be provided consistently over the course of a year. The current reimbursement rate is $91 per unit in urban areas and $83 per unit in rural areas. Under the new system, the rate for one 15-munite unit would be $14.77 in urban areas and $13.47 in rural areas. According to DMAS, under the new unit and rate structure, the total expenditures would increase if the maximum limits are billed. However, with the new daily and weekly limits in the unit structure maximum yearly limit would be more difficult to achieve.

Chesapeake Integrated Behavioral Healthcare supports the 15 minute unit.