As a member of the Rappahannock Area Community Services Board, I have grave concerns about the reorganization of programs proposed by DMAS. These are very anxious times for our service providers, given the high level of unrest and unease in our country right now, especially related to financial matters. 

 

This specific policy impacts our MH Residential Programs.  If we assume the maximum reimbursement rate and maximum number of hours per month are received per individual served and use last fiscal year’s expenses, these changes would result in an -$1,099,030.09 deficit across the impacted programs.  In addition, there are currently no LMHP staff for these programs.  These changes would require a program-specific clinical director and one additional LMHP for every 9 staff members.  RACSB would need to add 1 Licensed Program Specific Clinical Director and 2 additional LMHPs to support MH Residential alone. This would equate to an additional -$334,070.84 deficit to the program.

MH Residential would have, at minimum, an -$1,433,100.93 deficit per year.

This does not include the additional costs of increased training requirements, significantly increased supervision requirements, significantly increase administrative burden/documentation/complex authorization, etc.  Further, it does not calculate the costs of the requirement to have 24/7/365 coverage provided by an LMHP (Licensed provider).  The number above is a significant underestimation of the actual deficit.  However, I don’t have enough information today to begin to calculate the addition impact.

Further, due to the limits in maximum hours of care for individuals receiving services, our individuals served can expect to see an 87% reduction in the hours of service eligible to receive, or an approximate reduction of 134 hours of care per month or 1,608 hours reduction of care annually per individual.

In simple terms, we would lose significant funds and provide a distressingly and potentially dangerously lower level of services under this proposal. We are currently running effective programs with well-trained staff, getting excellent results, even though we are, of course, not meeting everyone's needs all the time. This proposal would undercut our efforts and give us a tremendous setback in our current efficiency. 

Please reconsider and either scrap, delay, or significantly revise this proposal, giving local boards time to give input and study the results more thoroughly.