In Chapter II on page 9, there is language stating that providers must report adverse outcomes for individuals who have been discharged within 180 days of an adverse outcome.  We do not remain in contact with clients post discharge as we are no longer providing services, we do not consider their information to be able to be used by us based on human rights regulations, and many times they do not wish to remain in contact.  We do not have the manpower to remain in contact with clients for 180 days post discharge with no compensation.

Throughout the manual, Trainees at the QMHP level are referred to as QMHP-E.  Our understanding is that these are now referred to as Trainees by the Board of Licensing who are now governing the qualifications of this level of prospective employee. 

In chapter IV on page 62, there are changes to the service requirements for Crisis Stabilization.  One change is removing the language, "as appropriate" in reference to a psychiatric evaluation and making it a requirement for every admission.  While there are certainly times in which a psychiatric evaluation and pharmaceutical assessment are indicated, there are many times in which it would be redundant or unnecessary.  Most of the clients who come into Crisis Stabilization already have an established relationship with a psychiatrist and while there are certainly cases in which a client may be experiencing heightened symptoms due to a need for a change of medication regimen, the nature of crisis stabilization is that they have had a precipitating factor which has necessitated the need for Crisis, not a needed medication change.

Crisis Stabilization is a valuable option to clients who are being disharged from a pschiatric hospital admission as a step-down service to get them reconnected into the community and provide support through the transition back home.  In these instances, they have been seen regularly throughout their psychiatric admission and would have a follow-up appointment already scheduled.    In these instances, an evaluation is not always needed.  Lastly, Crisis admissions can be very short and there may not be opportunity for the client to see a psychiatrist in the time that they are in services. 

Also, in this section, it states that counseling should be provided by LMHP or LMHP-type.  There is no indication of frequency or if the services would be billed as counseling or under the code for Crisis Stabilization.  In other words, is this coordination of services to a counselor, or counseling given as a part of the service.  Clarification on this would be helpful.

Thank you for your consideration of all comments on the proposed changes.