Comment on Virginia Medicaid 1115 Waiver Application

October 19, 2018

Dr. Jennifer Lee, Director

Virginia Department of Medical Assistance Services

RE: Mental Health America of Virginia (MHAV) Comment on the Medicaid Expansion 1115 Waiver

Dear Dr. Lee:

Founded in 1937, MHAV is the oldest mental health advocacy organization in Virginia. Our mission is to educate, empower and advocate on behalf of individuals, communities, and organizations to improve mental health. We are working toward a time when all Virginians achieve optimal mental wellness. Expanding the number of Virginians eligible to receive Medicaid, and also expanding the range of Medicaid reimbursable services, are important steps toward realizing this vision.

MHAV is writing to support inclusion of reimbursement for supported housing and employment services contained in the 1115 waiver application. National data continues to prove how integral all social determinants of health are in helping people experiencing mental illness live self-determined lives in their home communities. Safe and stable housing and meaningful employment are particularly important for facilitating strong recovery; recent research indicates that for many people living with mental illness, addressing their core needs for housing and employment more effectively supports self-determination and recovery than does clinical mental health care.

While we cannot voice our appreciation for the inclusion of housing and employment supports loudly enough, we are also deeply concerned about proposed monthly premiums for individuals with income between 100-138% of the federal poverty level.  Many of the adults our affiliates work with and advocate for within this income range are already not able to cover their basic human needs, especially in high cost of living portions of the Commonwealth such as Northern Virginia and Charlottesville. While some will qualify for a TEEOP exemption, others will not. Denying these Virginians access to Medicaid because they cannot afford the monthly premium will not prevent them from utilizing high cost care, such as Emergency Departments. It will simply mean the care they do receive is not reimbursed, which in turn drives up health care costs for everyone.

In summary, MHAV views the inclusion of supported housing and employment services in the 1115 waiver application as progressive and recovery-oriented thinking that will result in improved outcomes for our friends, family members, and neighbors living with behavioral health needs. We appreciate the need to promote the assumption of personal responsibility for health outcomes and feel that can be achieved through more equitable means than the proposed monthly premium. We are thrilled that after five long years of advocacy Medicaid expansion has come to Virginia! Thank you for this opportunity to comment on the 1115 waiver application.


Bruce Cruser, Executive Director

Anna Mendez, President, Board of Directors