1) Proposed updates for Community Stabilization criteria reads as though a client may only be referred by one of the sources listed in order to access the service. Is it the intention that a professional indicated under admission criteria section 3.b.i or 3.b.ii are the only ways in which someone could access the service versus the current ability for a self referral or referral from a provider such as a doctor/school/counselor etc?
2) Language regarding the behavioral health crisis having occurred within the last 72 hours seems to have been removed. Is it the intention for the service to become focused on clients actively in crisis/at the recommendation of one of the approved referral sources?
3) Requiring a preauthorization puts providers at the mercy of MCOs approving a service prior to initiating services. There is no timeframe indicated for which the MCO is responsible for providing a response to a submitted preauthorization request. LMHP-types are already required to assess in order to initiate the service. Implementing preauthorization, as opposed to the current process of registrations seems counterintuitive to the purpose of providing a crisis service that in intended to offer immediate support and delay the implementation of crisis services clients actively in need.
4) Both mobile crisis and community stabilization proposed regulation updates indicate that care coordination must be inclusive of contacting that person's MCO for service coordination. As involving the MCO as part of care coordination was not specifically outlined previously, are the MCOs prepared to handle this influx if this will now be a required part of crisis services?
5)For providers that include peer supports as part of their services, I would encourage consideration for allowing them to be part of of the care coordination process, as they often assist, in their roles, in providing effective community supports that will be of benefit to the client.