The VACBP strongly supports the goals of Behavioral Health Redesign. As we continue to participate in the redesign process, we will maintain a focus on the following priorities:

---

Ensuring that the redesign results in a comprehensive continuum of care for community-based services that includes strong prevention and recovery components, is trauma-informed and evidence-based where possible, and enables individuals to easily move from service to service without gaps in coverage so that the most appropriate care can be accessed.

Early intervention and prevention services, including outpatient supports, should be built into the continuum. Early intervention services can not only help reduce the state’s Medicaid costs, but also provide cost avoidance, recognizing the resources that are needed when individuals who don’t receive the care become more sick, are incarcerated, homeless or otherwise unable to care for themselves. ​

The chronic nature of behavioral health challenges must be recognized. Serious mental illness is no different than other chronic conditions that require ongoing care, like diabetes or heart disease. Incorporating tiered services with lower cost/lesser intensity services that can be provided over an extended period of time can be critical to helping patients manage their conditions and maintain healthy living. This can lead to better health outcomes and longer-term stability for the patient, decreased need for crisis services, and lower overall healthcare costs.

It is important to have greater clarity and consistency in service definitions, diagnostic and clinical necessity criteria, level of care descriptions and service requirements. Regulators, payers and providers must have a shared and consistent understanding of services throughout the continuum of care. This will increase consistency in authorization decisions within and between the MCOs, better care coordination by payers and providers, and a more efficient and effective delivery system.

Reimbursement rates must more appropriately reflect the true costs to provide services. This should include, but not be limited to:

• Costs associated with the use of evidence-based practices
• Administrative costs to navigate MCO processes, including an increase in the number of authorization requests that must be submitted
• Increasing staff qualification and supervision requirements
• Use of technology (i.e., EHR systems, data collection, telehealth)
• Costs associated with national accreditation attainment (i.e., CARF or COA)
• Professional liability insurance costs
• Ongoing training and professional development for staff
• Increases in the overall cost to do business (i.e., wages, benefits, rent)

The experience, expertise and availability of private-sector, community-based providers must be more comprehensively integrated into all pieces of the continuum. Enabling a significant and increased role for quality-focused, private-sector community-based providers will help to maximize constrained Medicaid and General Fund dollars and reduce unnecessary investment in services that are already available today in the private sector. Greater utilization of private-sector providers will also ensure Virginia’s Medicaid recipients are able to access an appropriate and cost-effective level of care in a timely manner, avoiding significantly higher costs if that care were not readily available. With this, it is equally important that all properly licensed and qualified providers be able to provide all community-based services, receive the same reimbursement for all services and that licensing, qualifications and supervision requirements be consistent across all providers, public and private.

Learn more about Behavioral Health Redesign

---

The transformation of our system is coming and will significantly impact every provider in Virginia. Join us to ensure your voice is heard. Already a member? Join our Behavioral Health Transformation Vision Initiative.