A summary of feedback provided by our members on this section follow:

Accreditation and Licensing

• Provider specialty is missing from the draft, creating uncertainty about accreditation requirements.
• Accreditation and licensing are time-intensive and costly, with deadlines (e.g., January 2027) that don’t align with real-world timelines. Agencies often must operate for a period before accreditation can even be granted.
• Requiring both external accreditation and DBHDS supervision is duplicative and unnecessarily burdensome.
• The costs of accreditation and ongoing compliance (admin, oversight, training) are significant for a Medicaid service provider.

Service Definitions and Clarity

• Restorative skills training vs. practice rules are unclear and inconsistent (telehealth allowed for training but not practice).
• Ambiguity around psychotherapy—whether it is part of CPST or a separate, billable service—creates risks of billing errors and service gaps.
• Functional impairment criteria (e.g., needing 2 vs. 3 domains across different levels of care) are contradictory and confusing; simplification is needed for consistent application.

Workforce Sustainability

• The draft places an increased emphasis on LMHP involvement, which is not feasible given Virginia’s severe LMHP shortage.
• Without state-supported solutions (higher reimbursement, loan repayment, workforce incentives), requiring more LMHPs will reduce—not expand—access.
• Flexibility should be allowed for alternative staffing models, including LMHP-types under supervision and telehealth-based oversight. Without this, many agencies may scale back or close services.