The VACBP provides industry leadership to advocate for public policies that reward efficient and effective community-based behavioral health services. As we seek to improve Virginia's behavioral health delivery system, our priorities include:
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Develop a continuum of care that enables access to the most appropriate level of service in a timely manner in a setting that best meets the patient’s needs.
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Implement strategies to address the critical shortage of qualified behavioral health workers in Virginia.
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Ensure reimbursement rates more appropriately reflect the true cost to deliver care.
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Support and encourage data- and outcome-informed treatment.
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Support greater certainty and stability in the behavioral health delivery system.
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Increase the integration of medical and behavioral health, leveraging both the public- and private-sector providers.
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Better leverage the experience, expertise and availability of private-sector behavioral health providers.
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Improve accountability throughout the behavioral health delivery system, to include providers, payors, regulators and administrators.
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Protect and enhance consumer choice in behavioral health treatment.
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Increase coordination within and among agencies related to behavioral health service delivery and social service programs.
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2020 General Assembly Report
The following provides an overview of our efforts this session.
Reduce administrative burdens for providers and improve MCO-provider communications
Among the VACBP's top priorities for the 2020 session was to reduce the administrative burdens and uncertainties faced by behavioral health providers following the transition of Medicaid to managed care. Providers are currently experiencing the following challenges:
As a result of our efforts, language was included in the state budget that will make the following improvements:
Language has also been included in the state budget that requires DMAS to track and report on compliance with NCQA response time standards for each MCO, broken down by service type. Included in this tracking is how often total response times exceeds the NCQA standards and how often appeals are filed and of those, how often services are subsequently approved or denied. DMAS is required to report on this information on a quarterly basis and the reports are required to be posted on the DMAS web site.
A number of items we had requested was not included in the language, including:
We plan to continue working to advance these and related priorities to allow us to work as efficiently with the MCOs as possible and to ensure service can be available to those who need it in a timely manner.
Among the VACBP's top priorities for the 2020 session was to reduce the administrative burdens and uncertainties faced by behavioral health providers following the transition of Medicaid to managed care. Providers are currently experiencing the following challenges:
- Delays in treatment for patients due to slow MCO response times to service authorization (and re-authorization) requests
- Uncertainty regarding the status of service requests for patients and the providers who treat them
- Frequent claims by MCOs of missing/lost paperwork and duplicate requests for documentation previously submitted, further delaying treatment
- Inconsistent service authorization protocols among the MCOs
- Lack of written notification of authorization decisions from the MCOs
- Excessive wait times and frequent transfers from person to person when contacting the MCOs by phone
- Lack of transparency in service authorization approval processes and criteria used to determine if providers will be included in an MCO’s network
As a result of our efforts, language was included in the state budget that will make the following improvements:
- Ensure MCOs are complying with the National Committee for Quality Assurance (NCQA) response time standards (available here)
- Clarify that required response times are based on calendar days, not business days
- Require that, in those cases where a service authorization or reauthorization is not approved or denied within the NCQA response time standard, the provider shall assume to have approval to provide the service and receive payment until date of denial
- Clarify how MCOs are to determine if a service authorization is considered "urgent" or "non-urgent" as it pertains to the NCQA standards
Language has also been included in the state budget that requires DMAS to track and report on compliance with NCQA response time standards for each MCO, broken down by service type. Included in this tracking is how often total response times exceeds the NCQA standards and how often appeals are filed and of those, how often services are subsequently approved or denied. DMAS is required to report on this information on a quarterly basis and the reports are required to be posted on the DMAS web site.
A number of items we had requested was not included in the language, including:
- Require the MCOs to provide written notification by email or fax that a service authorization or reauthorization is approved or denied
- Require the MCOs to share the criteria used to evaluate whether to include a provider in their networks
- Require that when an MCO terminates an agreement with a provider without cause, the MCO will provide a written explanation of why the provider does not meet the MCO's criteria to be in its network
- Require DMAS to track and report on how often service authorization submittals are considered incomplete
- Require DMAS to track and report on how often peer reviews are requested and of those, how often are services subsequently approved or denied
We plan to continue working to advance these and related priorities to allow us to work as efficiently with the MCOs as possible and to ensure service can be available to those who need it in a timely manner.
Advocacy Member Benefits
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VACBP Behavioral Health Improvement PACIn order to advance the VACBP's policy priorities, we need members of the General Assembly who understand and care about the issues that impact our industry. The VACBP Behavioral Health Improvement PAC provides an opportunity for providers to collectively provide financial support to those elected officials and candidates who are aligned with the VACBP’s policy priorities. Click below to learn more about our PAC and how you can get involved.
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Advocacy ACTION Alerts
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Overhaul of licensing regulations coming
DBHDS is currently working to overhaul the regulations that dictate how a provider operates, from governance, organizational structure, finances, employee records, orientation and training requirements, office hours, emergency preparedness, ownership succession, complaints and grievances, and much more. The VACBP is working hard to ensure the interests of providers are considered as the regulations are changed. Join our Advocacy Initiative to receive regular updates and to share your thoughts and concerns about the proposed changes. |
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Concerns with proposed guidance on requirements for 90 days of operating expenses shared (September 2019)
The VACBP’s primary concerns on the proposed interpretation of this requirement included how “projected revenue” is interpreted and the unreasonable requirement that cash/line-of-credit reserve be sequestered. To read the VACBP’s comments on this issue, click here. |
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Recommendations for DMAS rate study highlight need for investment in early intervention, higher rates and maintenance services (August 2019)
VACBP recommendations included a focus on increasing investment in early intervention and prevention services, development of rates that reflect the true cost to provide services, elimination of “rural” rates, development of a uniform assess rate across all community-based services and development of lower cost/lower intensity services that may be beneficial on a “maintenance” basis, leading to better health outcomes for certain patients and decreased overall costs that may otherwise come without some minimal level of support. To read the VACBP’s comments on this issue, click here. |