Regarding the Crisis Education & Prevention Plan, will there be more information provided and training for providers?

Mobile Crisis Response

• On page 8, under Required Activities (bullet #3), it states, "The Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements shall be required during the entire duration of any crisis services and must be current."  What constitutes current for the CEPP?  If it's completed within X number of days?
• The safety/crisis planning appears to be duplicative with the CEPP.  It is recommended that the CEPP be removed as a requirement in the Mobile Crisis Response and only require safety/crisis planning to avoid duplication of efforts and administrative burden.
• On page 11, bullet #3 indicates that Treatment Planning must be provided.  It is recommended that ISPs not be required for a services that is provided for no more than 72 hours.  The assessment will identify the needs and recommended disposition.  The plan of care/treatment plan can be included in the recommendations section of the assessment.    It is also recommended that any administrative burden and/or duplicative documentation be removed from this service.

Residential Crisis Stabilization Unit

• On page 32, under Service Limitations, it indicates "RCSUs may not be authorized concurrently with....."  It is recommended that the word authorized be replaced with the word billed.  While the services should not be billed concurrently, the providers can still have an active authorization.  Otherwise, this will pose a lot of administrative burden for providers and increase the likelihood of revenue loss.
• On page 33, bullet #5 indicates, "A seven day overlap with any outpatient or community-based services (including other crisis services) may be allowed for care coordination and continuity of care."  Please provide further clarification given the draft requirement that RCSU cannot be "authorized" with other community-based services.  Again, it is recommended that DMAS replace authorize with billed.