Regarding comment period ending 9/29/2021 and effective date set at 12/1/2021. The last day for Medicaid coverage of Crisis Intervention (H0036) and Crisis Stabilization (H2019) is 11/30/2021. Psychotherapy for crisis CPT codes (90839, 90840) are also covered through outpatient psychiatric services effective 7/1/2021.

If the comment period closes 09/29/2021, there will be a short time between the release of the final manual requiring rapid provider implementation.  This is especially concerning considering the staffing crisis that mental health system in Virginia is experiencing.