Mobile Crisis Response:

Code of Va. mandated activities for Emergency Services not being carved out continues to lead to some potential confusion including by MCOs who do not always understand the activity and mandated role.   

Draft Regs are inconsistent with the current status of system resources including regional crisis call centers which lack capacity and 24/7 resources which will be further impacted by the Marcus Alert and other Co-Response activity that could not be supported 24/7 but is essential to build upon.

Page 8, under Service Definition, “Mobile Crisis Response services are available 24 hours a day, seven days a week to provide rapid response, assessment and early intervention to individuals experiencing a behavioral health crisis”.   Recommend notation of status referenced above.

Page 11, under Required Activities, the first bullet states “The provider must engage with the DBHDS crisis call center and crisis data platform prior to initiating services”.

• This does not align with needs or concurrent discussion regarding the call center/data platform capacity.  There are contradictory statements of requirement with assessment “at the start of services and that crisis data platform must be engaged “prior to initiating”.
• Engaging call center / data platform delays critical response placing priority on activity unrelated to clinical necessity or activity to assess or assist in resolving crisis in the immediate.

• For a Certified Prescreener – this service is mandated once the ECO has been issued and for the need to assess for the need of involuntary hospitalization.  
• Recommended that the requirement be removed as it is related to mobile crises or specifically mandated role of CSB Prescreener or mobile response (Marcus).