Legislative Priorities 2017

Overregulation continues to plague providers costing millions of tax payer dollars that could go directly to patient care.  Providers feel micromanaged by payers and licensing bodies, this leads to less care for the patient.

  • We support revising the licensing rule for behavioral health providers – 64(CSR)11
    • It should include extending the license from 2 years to 3 years.
    • Deemed Status for accredited providers.
    • A focus on being helpful and not punitive.
  • We support an exemption of the new Medication Assisted Treatment (MAT) rule for licensed behavioral health providers.  This is a duplicative and over burdensome rule that will result in less options for persons suffering from opioid addiction.
  • We support an exemption for behavioral health providers from the new tele-health law.  This law was intended to stop opioids from being prescribed using tele (video) medicine.  Due to the rural nature of West Virginia we rely heavily on the use of technology to reach underserved areas.  This law prevents children with ADHD from accessing services in their home area.
  • We support revising the fee-for-service (FFS) model used in funding the IDD Medicaid Waiver.  We support daily rates and/or a PMPM funding methodology that allows providers to deploy their staff without reprisal from licensing and payers.
  • We support one Criminal Background Check process for determining who providers can hire.  Right now there are two within DHHR, this needs to be collapsed into one unit.
  • Behavioral health providers are faced with two separate visits to inspect for life safety related to the fire code.  First, by the Fire Marshall and a second by the licensing body OHFLAC.  Each use a different fire code and often times they send conflicting messages.
  • Medicaid has an ASO that visits providers annually, in the past this was every two years.  In addition, to site visits by the ASO – there are visits by OHFLAC, the Fire Marshall, Health Department and others.  There are expenses associated as providers respond to each entity.  We support streamlining these processes to reduce regulatory burdens and ensure client safety.  Other states have one model for review in WV we have multiple.
    • At the same time, more dollars are being driven toward unlicensed entities that are not subject to these rules.
  • We support a cost benefit analysis on each existing rule and all new rules to ensure that our tax dollars are best spent on effective care rather than government bureaucracy.