We share many of the same concerns as prior comments regarding turnaround times for service authorizations and if there will at least be a minimum number of units to ensure the agency can work with a client for a set amount of time if the authorization has not been sent. 

Page 36, "The referring provider must determine what other services the individual is receiving prior to referring to Community Stabilization. It is the responsibility of both the referring provider and the Community Stabilization provider to determine if the individual has another community behavioral health provider and should contact the MCO/FFS contractor, caregivers and natural supports prior to initiating Community Stabilization services."  Currently, several MCOs (including Optima and Virginia Premier) will not share what authorizations a client has open at the time of admission to a new provider, citing a "HIPAA violation." Our agency already checks for existing Community Stabilization authorizations before assessing a client to avoid duplications in services and are unable to verify the status with those 2 MCOs consistently, and occasionally with United Healthcare. There is not a current means to reliably check the status of current authorizations without MCO engagement and they'd need to be informed to release the information unilaterally, across services to include IIH, TDT, and MHSS if Community Stabilization providers are expected to know a client's status in those services at admission.