On Page 8, under Service Definition, it says 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”. Our mobile crisis team is not available 24/7 as of yet and will not be for several months to a year. This requirement will cause the team to be out of compliance. It is recommended that this requirement be removed until all regional mobile crisis teams are available 24/7.
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 requirement will lead to increase call volume that call centers do not have capacity to receive. It is recommended that the requirement be removed totally or amended to require engagement with the data platform only.
On Page 15, under Staff Requirements, the billing structure and team composition only allows a peer to provide services when paired with another professional. In crisis response, there are many instances that a peer can independently engage, support, transport and perform activities that will assist with the de-escalation of a crisis episode. It is recommended that peers be allowed to bill independently for Mobile Crisis Response services if the individual has been assessed and determined that peer recovery services are appropriate to assist with crisis resolution.
On Page 18, under Service Authorization, it states that the registration permits eight hours (32 units) in a 72 hour period”. Billing should be allowed for the entire time that the service is permitted, which is 72 hours. It is recommended that Mobile Crisis Response be permitted for billing up to 72 hours.
