The Behavioral Health Commission received a briefing by Commission staff at its October 17 meeting and approved a series of recommendations intended to improve oversight and enhance the implementation of STEP-VA, an initiative first enacted in 2017 to standardize an array of core services to be offered by all Community Services Boards (CSBs). The nine services required under the 2017 legislation have been phased in to allow time for funding to be provided; six of these services have been implemented to some degree, with the last three services expected to be available statewide by July 1, 2024.
Commission staff found that the statutory mandate establishing the STEP-VA initiative and setting out the services to be provided is unclear, lacking specificity with regard to populations to be served and the type of services to be offered. Staff also explained that services have not been fully deployed statewide as originally intended, due in part to funding constraints, which have been exacerbated by inconsistent billing for Medicaid-covered services, as well as workforce challenges at CSBs. Staff also found that performance measures and benchmarks, when they have been adopted, do not adequately assess the quality of STEP-VA services, and that the CSBs’ data system is a barrier to data collection and reporting. The Governor’s Right Help, Right Now initiative includes elements that align with STEP-VA’s goals, such as the focus on improving the crisis response system and the planned implementation of the Certified Community Behavioral Health Clinic Model.
Key recommendations approved by the Commission in concept include the following:
- Clarify the intent of the STEP-VA initiative regarding access to essential behavioral health services and the scope of the STEP-VA service components that CSBs are required to provide to achieve full implementation.
- Direct the Department of Behavioral Health and Developmental Services (DBHDS) to work with the Department of Medical Assistance Services (DMAS) to assess the extent to which CSBs are billing for Medicaid-eligible services and provide technical assistance and training on appropriate Medicaid billing and claiming practices.
- Direct DMAS to work with the managed care organizations involved with the state’s Medicaid program to standardize, to the maximum extent practicable, policies, procedures, and requirements that CSBs must follow to receive reimbursement for Medicaid-funded services.
- Direct DBHDS to report annually to the State Board of Behavioral Health and Developmental Services and to the Behavioral Health Commission on average salaries, turnover, and vacancy rates, by position type, across community services boards.
- Direct DBHDS to amend CSB performance contracts to require that any funding appropriated by the General Assembly to CSBs for staff compensation be used only for staff compensation.
- Direct DBHDS to identify all current requirements of CSB direct care staff related to documentation and reporting of behavioral health services that are duplicative or conflicting and eliminate non-essential requirements.
- Direct DBHDS to (i) finalize performance measures for every STEP-VA service component that has been initiated statewide, and (ii) finalize benchmarks for every STEP-VA service component that has been initiated statewide and to report these benchmarks to the House Appropriations and Senate Finance and Appropriations committees and to the Behavioral Health Commission by December 1, 2024, and December 1, 2025, respectively. Direct DBHDS to report to the Behavioral Health Commission on the changes made to community services board performance contracts related to revised performance measures and benchmarks for each STEP-VA service component by December 1, 2024.
- Direct DBHDS to conduct a needs assessment to determine the unmet need for each of the nine service components of STEP-VA and develop an estimate of the cost of satisfying the unmet need for each of the nine STEP-VA service components statewide, with a report due by December 1, 2024.
- Direct DMAS to (i) ensure that comprehensive information about all available managed care organization preferred provider programs (which reduce administrative complexity by eliminating requirements for prior authorization for certain services) is provided to all CSBs.
- Direct the Secretary of Health and Human Resources to report to the House Appropriations and Senate Finance and Appropriations committees and to the Behavioral Health Commission by December 1, 2024, on plans to implement the Certified Community Behavioral Health Clinic (CCBHC) model in the Commonwealth. Direct DMAS to examine how Virginia can most effectively and efficiently transition to a prospective payment system as required to fully adopt the CCBHC model.
Staff plans to provide Commission members with draft legislative and budget language for consideration at the Commission’s December meeting. The Commission meets next on November 13.
VACo Contact: Katie Boyle