I would encourage further discussion regarding billing practices for TDOs and ECOs.  The updated TDO supplement manual now includes any non Medicaid eligible individual to be covered under the TDO/ECO program.  Per the updates:

"For Prescreening Assessments:

Claims for CSB prescreening assessments conducted through emergency services may be submitted to the TDO Program for:

• non-Medicaid eligible individuals under emergency custody pursuant to 37.2-808 or 16.1-340 of the Code of Virginia;
• non-Medicaid eligible individuals not in emergency custody if the prescreening assessment results in a TDO; and
• subsequent prescreening assessments conducted while a non-Medicaid eligible individual is under a TDO.

All prescreening assessments are billed under the H2011 HCPCS code and the appropriate team modifier.  See Appendix G of the Mental Health Services Manual for additional details.  DBHDS Virginia Crisis Connect requirements apply but providers are not required to submit a registration form to the TDO Program."

According to Appendix G in the Mental Health Services Manual, currently preadmission screening require a registration and are listed under the Mobile Crisis Services.  Allowable billing is 8 hours within 72 hours.  If additional hours are needed, per Appendix G, "If additional time is needed, including time on the last day of the registration that exceeds the 72 consecutive hours from the time of admission, providers must submit a new registration form."

While the ECO period lasts 8 hours, it is rare that an individual is assessed and a bed is located within the 8 hour time period and they are placed in a facility under a TDO.  Often Emergency Services is providing care coordination through the duration of the 72 hour TDO period as a billable service, and may need additional hours past the 72 hours if the individual needs a bedside hearing and is still receiving care coordination and placement efforts well beyond the 8 hour ECO and 72 hour TDO bed placement period.  Clarification for ability to bill the ECO/TDO fund for time spent for the ECO, TDO, and subsequent prescreens completed while the individual is under a TDO is essential.  It is recognized that a registration will not be required but clarification as to reference of billing practices per Appendix G as to additional hours allowable to bill services.  Clarification as well for billable services that span multiple days, due to execution and completion of ECO/TDO over several days due to the nature of 24/7/365 Emergency Services service delivery.