NAMI Virginia’s members consistently rank a lack of supportive housing as the number one problem facing people with mental illness in Virginia. Lack of appropriate, supportive housing is a significant barrier to maintaining stability, long-term recovery, and living successfully in the community. Recent legislative initiatives to expand supportive housing have helped address this long-standing problem. We would like to thank lawmakers and state agencies for their support of HB 675 in the 2016 General Assembly Session, which is helping Virginia move closer towards a model of integrated, community-based supportive housing.

Upon review of the draft regulations and guidelines developed by the Department of Behavioral Health and Developmental Services (DBHDS) and Auxiliary Grant in Supportive Housing (AGSH) Advisory Workgroup, NAMI Virginia submits the following comments on the emergency draft regulations and guidelines:

We support the application of auxiliary grant program standards to DBHDS licensed supportive housing providers and including licensed community based mental health supports services in the AGSH rate.  Requiring that individuals in the AGSH receive an equivalent level of service to those in assisted living, in conjunction with the Housing First principles adopted by the AGSH Advisory Workgroup, demonstrates effort to adopt best practices and support recovery.

The regulations provide that the Universal Assessment Instrument will determine eligibility for AGSH, and “[e]ligible individuals shall be notified of the SH setting option and the availability of approved SH providers at the time of their annual level of care assessment.” Under this process, AGSH is offered to qualified individuals at the time of annual assessment.  The regulations appear to restrict this process to individuals currently residing in assisted living facilities. 

There is no reason to limit access to the AGSH only to those qualified individuals who reside in ALFs. The Uniform Assessment Instrument has been adopted for use by all publicly funded long-term care services, according to the official User’s Manual for the UAI. Therefore, the regulations should recognize a process for the identification of supportive housing in the UAI while an individual is residing in a state mental health facility prior to discharge. This process would be consistent with the language of Virginia Code, Section 51.5-160(E), stating that an individual may select supportive housing at the time of the first annual assessment.  

We are truly grateful for all of the effort that state agencies and other stakeholders are making in launching this important program. We ask that you please consider our comments as you finalize the changes to 22VAC30-80 and refine the program guidelines. Thank you.