Given we have a 12/1 start date to implement changes that involve:

• Call centers that are not yet operational.
• A crisis assessment tool that has not been formalized so providers may prepare for implementation (which requires training and EHR integration).
• A CEPP that is required, but again, not formalized so providers may prepare for implementation.
• A multitude of CPT changes which could change at the time of the final regs being released maybe 3 weeks prior to 12/1 (which again, requires significant work on the EHR end of things).
• Several critical questions have been asked at last week's webex's that will inform agencies of process, needs, documentation, etc. and we are awaiting the FAQ's.

Taking these things into consideration, I believe many would appreciate a grace period for "going live" until these details are formalized and a reasonable time to establish and train on new processes as well as manage the data, billing, and EHR documentation changes required as a result.

I also have some concern that the 23hr model indicates we will only be able to bill one day for that service, yet there is a code for billing at TDO day which typically spans more than one day. Does this mean we will not be reimbursed if someone stays in the 23hr model more than one day, despite the fact that we have an order in place for them to be there?

The crisis/psych/nursing assessment all being required at time of admission or day of admission- the wording isn't clear what that expectation is and while I appreciate the effort shared in providing some allowances by doing that, establishing a time frame that will allow someone to be admitted and flow through acclimating to the center and sharing their story in a trauma informed way would be preferable.

I'd like to comment that for community crisis stabilization, "convenient and appropriate setting" could end up being an agency site. We work with individuals who live in tents or have hostile and destabilizing home environments at times and being reassured that we have the ability to work with them on stabilization in those environments would be appreciated.

I also agree with statements related to the nursing issues and the crisis hotline requirements.