Objective 2 of the DBHDS strategic plan includes a reduction of administrative burden for community providers of services. As a result, a team was developed to identify, review, and determine the state regulations related to documentation that have the largest impact on direct care staff across Virginia’s 40 local community services boards (CSBs).

For this report, the scope of review was narrowed to only documentation impacting the functioning of behavioral health direct care staff at the CSBs. DBHDS acknowledges there are global system level issues that play a significant role in administrative burden; however, those issues are not what the direct care workforce shared as a concern. These issues will be mentioned in recommendations for the future as part of this report.

To prepare this report, DBHDS used a list of requirements and regulations for the provision of service at the ground level and interviewed CSB direct care staff. The focus of these interviews was to gain an understanding of any issues related to administrative burden and how those issues may affect job performance.

There are several factors complicating a statewide reduction of administrative burden:

• The number of different entities who set and maintain regulations related to direct care include but are not limited to DBHDS, the Department of Medical Assistance Services (DMAS), the Office of Children’s Services (OCS), Department of Health Professions (DHP), and the Commission on Accreditation of Rehabilitation Facilities. As regulations are changed, the entities involved must stay in alignment with each other as independent alterations. This may result in a reduction in paperwork, but limits CSBs’ ability to bill for services.

• Not all providers use the same electronic health record (EHR); therefore, requirements listed in the regulations are framed differently for staff within the record depending on the capability of their CSB’s EHR. As such, some CSBs can cross populate answers to eliminate any duplicitous information, while others cannot. The cost to upgrade networks and infrastructure for the providers may be above what they can afford.

• There is a significant number of referring sources direct service providers must interact with when delivering services. For instance, an individual may be court ordered, have significant legal issues, employment expectations, medical complexity, or family involvement, all of which require additional documentation and follow through from the direct staff. It is possible that this is a result of the rise in acuity of individuals seeking care following the COVID-19 pandemic. CSBs are reporting their populations needs and concerns are rising while their ability to meet those needs is remaining stagnate or decreasing due to ongoing workforce issues, regulatory expectations of level of certification for job tasks, and locality limitations where some recommended services are not sustainable.