Nevada Psychiatric Association

2590 E. Russell Rd
Las Vegas, NV 89120
Office: 702.623.4319
Fax: 702.463.3943
www.nvpsychiatry.org

Ms. Marta Jensen, Administrator

Department of Health and Human Services
Division of Health Care Financing and Policy
State of Nevada

August 10, 2018

Dear Ms. Jensen:

The Nevada Psychiatric Association (NPA) wishes to express its concern regarding the proposed
changes to the Medicaid Services Manual which will require prior authorization for
psychotherapy services for Nevada Medicaid recipients. While the adjusted proposal which now
suggests the prior authorization be submitted after three visits for an evaluation is an
improvement, the idea that psychotherapy can be simply approved by unnamed and therefore
unknown individuals who may or may not have an expertise in either diagnosing or providing
therapy to our patients is unacceptable.

Psychiatrists now do much less psychotherapy than in past eras, therefore we are dependent on
our non-medical colleagues to provide much of it to our patients. Psychotherapy has been shown
to decrease utilization of other mental health and medical services, to reduce losses from sick
leave, and to promote well-being of children. While there is reason to evaluate why a given
individual might stay in therapy for many years, studies show that longer therapies produce more
durable results. The cost of 26 or some other pre-determined number of sessions of therapy is
less than most single diagnostic tests and therefore artificial limits are pound-foolish, penny wise
decisions. This will also likely lead to even more bureaucratic layers which cause the
therapist/provider distress and will contribute to the dearth of mental health care providers in
Nevada. We would also expect increasing costs of domestic violence, imprisonment,
homelessness, and the other social problems that result from untreated psychosocial distress,
substance use, and mental illness. Additionally, many programs which are grant funded, such as
medication assisted treatment (MAT) of opioid use disorders, require ongoing counseling and
psychotherapy to be effective and also to maintain their funding.

Thank you for your consideration and we are happy to respond to any questions or concerns.

Lesley R. Dickson, MD
State Legislative Representative
Nevada Psychiatric Association
Lesleyru@aol.com
702-349-5378