On Page 22, under Service Definition, it says “Community Stabilization services are available 24 hours a day, seven days a week, to provide for short-term assessment, crisis intervention, and care coordination to individuals experiencing a behavioral health crisis”. All regional mobile crisis teams are not operational 24/7 and this requirement would lead to automatic noncompliance. It is recommended that this requirement be removed until all mobile crisis teams are available 24/7.
On Page 24, under Required Activities, the first bullet states “The provider must engage with the DBHDS crisis data platform prior to initiating services.” Please define the term “engage”. It is recommended that “prior to initiating services” be removed and replaced with “as services are initiated”. Services should be client-centered and aim to assess prior to engaging with data platform. The revision gives flexibility to providers as services are being started.
On Page 27, under Admission Criteria, there is a requirement that an individual must be discharged from one of the 10 services or settings in order to access/provide the Community Stabilization service. The requirement disregards the notion that clients can experiencing a crisis while receiving another community-based service such as case management or TDT. This limits access to this service and forces the individual to wait until the crisis is acute before the service is accessible. It is recommended that the services be allowed and accessible at any point as long as admission criteria are met.
On Page 30, under Exclusions and Service Limitations, #1 indicates that an individual receiving MHS or ARTS services “more intensive than standard outpatient psychiatric services for mental health and substance use disorder,…” The term “outpatient” is used differently and can many services can be placed under that general term. Please clearly define “outpatient psychiatric services”. It is recommended that individuals who are connected to outpatient services have access to this services as crises are experienced by these individuals as well. This would exclude individuals in case management, TDT, medication management or therapy.
On Page 32, under Staff Requirements, peers are not allowed to provide services independently. It is recommended that peers be allowed to provide Peer Recovery Services without the presence of another professional. The best engagement is often times when peer-to-peer services are provided independently.
On Page 34, under Service Authorization, Community Stabilization no longer allows for registration. It is recommended that the registration process remain for this service and the timeframe be shortened, if necessary.
