I am not sure if you are trying to draw a differentiation between Crisis Intervention and Crisis Treatment or Short Term Crisis Counseling. Crisis Treamtent is newly defined at the being of Chapter IV and Crisis Intervention is defined later under covered services.  Crisis Intervention can be provided by a certified prescreener. Crisis Treatment is defined as needing to be available 24 hours a day seven days a week to provide immediate assistance to individuals, which sounds like the old definition for Crisis Intervention. Furthermore, Crisis Treatment is listed as an activity of Crisis Intervention, however, the proposed revision does not include a certified prescreener as an approved provider for Crisis Treatment or Short Term Crisis Counseling. Only LMHPs and LMHP types are listed as approved providers.

I would also like to say that I believe the requirement to compete a Comprehensive Needs Assessment in the midst of a crisis does not faciltiate good clincial practice. I think it is unreasonable to gather the extent of the information required when we are trying to also conduct a suicide risk assessment and accomplish hospital diversion. It is also unreasonable to require us to register that we have provided crisis intervention services within 24 hours. Crisis intervention services often occur after hours and on the weekend when reimbursement staff are not available. I urge you to reduce the amount of information we are required to gather, include a assessment of risk to self or others and inability to care for or protect self, and allow more time to register that we have provided a crisis intervention service.