Page 52; under service definition...

RCSUs provide short-term, 24/7, residential psychiatric and substance related assessment and brief intervention services. The service supports the following individuals:

• Individuals experiencing changes in behavior noted by impairment or decompensation in functioning that may result in the need of a higher level of care.
• Individuals stepping down from a higher level of care that need continued monitoring, stabilization and mobilization of resources.
• Individuals who need a safe environment for assessment, stabilization, and prevention of further escalation or decompensation. 

The above information is excellent, though it does not translate when looking at Medical Necessity / Admission Criteria

Medical Necessity / Admission Criteria #1 on page 58;

Individuals must meet all of the following criteria (1-5)*:

1. One of the following must be present:

a. The individual must be experiencing an active behavioral health crisis or

b. The individual is stepping down from a higher level of care after a recent behavioral health crisis and needs continued stabilization prior to returning to the community and...

**Can there be an option C added to address the individual we support who needs a safe environment for assessment, stabilization, and prevention of further escalation or decompensation?

 Exclusion Criteria and Service Limitations page 60-61;

1. RCSUs may not be billed concurrently with any other behavioral health service except when a service overlap with other community behavioral health services is needed as part of a safe discharge plan. Documented justification of the time needed for discharge planning and care coordination to other services is required. Overlap durations will vary depending on the documented needs of the individual and the intensity of the services but in no instances may exceed 48 hours.

**The above statement indicates that we are taking a few steps back and going back to and/or adding additional barriers for individuals moving through the crisis continuum and/or have a need for continuity of care.  Can you clarify, does this mean if a client has an open PA for another crisis service or behavioral health service (i.e. mobile crisis, community crisis stab., ACT, MHSS, etc.) that will overlap with a submitted R-CSU PA, the R-CSU PA will be denied? We provide services for many ACT clients and the language above sounds like this is going to be a more difficult challenge.

“Concurrently”, typically means at the same time, so can an individual have more than 1 crisis or behavioral health service PA active at the same time, just as long as, both services are not billing at the same time?  “RCSUs may not be billed concurrently with any other behavioral health service except when a service overlap with other community behavioral health services is needed as part of a safe discharge plan. Documented justification of the time needed for discharge planning and care coordination to other services is required.” - Can you clarify which service would need to provide the justified documentation?  If justifiable documentation is needed by insurance company, doesn’t that then become very subjective?

 Service Authorization; page 67

Providers must submit a registration to the individual’s MCO or FFS contractor within one business day of admission. The registration permits five calendar days/five units of service. Units billed must reflect the treatment needs of the individual and be based on the individual meeting medical necessity criteria.

**Can you verify, a registration, if submitted within 1 business cannot be denied by an MCO, since it is a registration and NOT an authorization?

“Continued stay requests are to be submitted no earlier than 48 hours before the requested start date of the continued stay and no later than the requested start date”

**Thank you for this, this is great news and much appreciated!

 Service Authorization; page 67

**the addition of 2 more documents to submit for continued stay requirement is adding to the administrative burden.  A current continued stay packet is roughly 35 pages with the addition of the ISP and Care Coordination notes it could be a 45-50 page packet. This can be an exhaustive clerical process to potentially ask for as little as 1 additional day of treatment. Please consider decreasing the number of documents needed for continued stay rather than increasing. This may have unintended consequences such as premature discharge given workforce shortages to dedicate extended time coordinating documents for MCO review with minimal clinical utility.