“Intent of CS is to folks that are being discharge to the community from a higher level of care to the community and the community services is not available at that time. Must be coming from another crisis services. “from Dr. Wards video. Does this eliminate Community based referrals from PCPs, Schools, other Outpatient therapist, case manager? As the guidelines are written in this draft, there is no pathway for these Community Providers to make direct referrals to CS which often is used when the consumer may be showing signs of escalating behaviors that place them at risk of a higher level of care. So, this language essentially eliminates that pathway to CS. The community will not be prepared for this shift and this may truly create a barrier to access for some and may result in higher utilization of Mobile Crisis-Responses and specifically Prescreening Evaluations, where staffing shortages have made it difficult or in some cases impossible to have fully functional mobile response teams.
Service Authorizations: As written in the draft a service auth will be required instead of registration, and that the units will be based on MNC. This creates the same level of inconsistency that was present prior to Dec 1, 2022 Comprehensive Crisis Changes, when depending on the MCO and even the MCO care coordinator reviewing the auth, services could be authorized for anywhere from 3 days -7 days. An authorization in place of a registration may leave consumers who are “in a crisis” waiting 1-2 days for the MCOs to approve the services as agencies may want to avoid the possibility of initial services being provided and not authorized.
Community stabilization proposed regulation updates indicate that care coordination must be included and involve the MCO for service Coordination. What does this include, calling the MCO and asking for providers. With major shortages of providers MCO has been sought out by CS provider to obtain information on providers in catchment area only to be told by several specific MCOs to “go on the website and search for providers” and not offering any valuable input to the care coordination process? What will be the MCOs role in the new regulation for Care Coordination?
Can you clarify the use of QMHP-E in Community Stabilization? As it is written now QMHP-E are only a part of the team composition with a LMHP. With agencies experiencing tremendous staff shortages it is crucial to be able to use QMHP-Es as part of Team composition 1 HN 1 QMHP-A or QMHP-C or 1 CSACx
