While Region 4 supports the long-term vision of the state for a single point of entry to the crisis services system when possible and appropriate, the regional crisis call centers are already expecting call volume to at least double with the implementation of 988 beginning 7/16/22 driving that system to operate at or above capacity. As such, we strongly recommend that any requirement of providers to coordinate or engage with the call centers be retracted. Providers should continue to engage with the DBHDS data platform, not necessarily call center personnel, to obtain a reference number, record and coordinate
care. Specifically, the draft regulations require coordination with the DBHDS crisis call center (under ‘care coordination’), engagement with the DBHDS crisis call center prior to initiating
services under ‘required activities’, and further requirement under ‘service
authorization’ to engage in required DBHDS call center engagement…according to
DBHDS guidelines.  The DBHDS data platform dispatch feature is not functional for
Region 4 at this time. As such, the call center personnel will be challenged beyond
capacity to both triage the crisis callers while simultaneously coordinating and
engaging with approx. 600 mobile response provider staff identified in Region 4,
as required in these regulations and in a manner that enables safe and
timely connection of resources for individuals. If DMAS cannot retract this language,
then at a minimum it needs to postpone implementation of this requirement
for at least 6 months until such time that the required features in the
DBHDS data platform are performing to standard and further clearly define
the terms “coordination and engagement” with call center to inform complex
operational workflows at local, regional, and statewide levels.