Pg 11 — Requires availability of an on-call LMHP 24/7, and unclear whether this can be provided by CSB Emergency Services or must be part of CPST Team. At times, this version refers to "internal" crisis supports, which sounds like the CSB's own emergency services could be used. If ES staff can be used, it looks like licensed-eligible staff would not qualify to provide this coverage. ES staff- licensed and licensed eligible have much more extensive training in crisis response and have an already established process for providing interventions.
Pg 15- Crisis plan requirements are extensive, Will require significant training and alteration of our documentation to ensure includes all the required components.
Pg 17- Adds requirement to contact MCO every time the individual accesses the crisis continuum. Additional burden to a staffing structure that is already taxed. Won't the MCO already know that a Medicaid service (crisis type or not) has been provided?