I am concerned as to the proposed regulations requiring an authorization for Crisis Stabilization.  Currently, receiving an approval for other services has a timeframe anywhere from 2 to 5 days; however, taking into consideration that a client has a crisis situation and is in need of immediate service, it does not appear to be conducive to the client's treatment if that client is having to wait for an authorization to be approved in order to have assignment of a trained provider to begin working with the client.  This would delay beginning the crisis service and potentially contribute to the client's increased symptoms, thus placing the client in the hospital.  An authorization for Crisis Stabilization requires an extensive amount of paperwork; therefore, this proposed regulation does not appear to have stability in meeting the client's needs effectively.  Also, as a valued member of the agency in which I am employed, if the intention is for the providers to begin services with the client in crisis without the approval, does or would this be a guarantee that the payment for the service is rendered if the authorization is eventually denied?  All in all, this would delay the beginning of services, which is instrumental to the client and could lead the client to seek other expensive avenues for services and intrusive higher levels of care. 

Thank you for your consideration in this matter,

Jenny Brummitt, BS,QMHP-A