Chesapeake Integrated Behavioral Healthcare would like to ask for clarification in the DMAS Mental Health Services Appendix G draft manual changes for Comprehensive Crisis and Transition Services - 

 

Page 9 - Required Activities for Mobile Crisis Services - Under the heading of 'Assessment' there are three bulleted items that are outlined as meeting the assessment requirement.  The third bulleted item states "Providers may use an existing DBHDS approved assessment for individuals transitioning from another crisis service or Community Stabilization.  At a minimum, an LMHP, LMHP-R, MMHP-RP or LMHP-S must review and update the DBHDS approved assessment."  Earlier in this same section it indicates that the prescreening assessment may be used to review and create an update or addendum to meet the assessment requirement if it has been completed within 72 hours prior to admission.  Does this same timeframe apply to the DBHDS approved assessment?

 

Page 36 - 23 Hour Crisis Stabilization Billing Requirements - the proposed guidance indicates that "if an individual is admitted to 23-hour Crisis Stabilization and it is determined that RCSU services are needed, the 23-Hour Crisis Stabilization provider should bill for the first 23.00 hours with the 23-Hour Crisis Stabilization (S9485) procedure code and the Residential Crisis Stabilization Unit (H2018) procedure code for any subsequent 24-hour period.  The provider should not bill multiple per diems for the first 24-hours of care and must request appropriate service registration for each service."  This does not appear to take into account that the two services may not be provided by the same provider. 

• For example, if Provider A is the 23-Hour Crisis Stabilization provider and it is determined that the individual would benefit from RSCU but they do not provide the service there would need to be a referral to Provider B.  Assuming the individual was admitted to 23-Hour Crisis Stabilization at 5am, the allowable time based on how it is currently written for Provider B to begin billing for RSCU would be at 5:01am the following day.  However, if Provider A determines that the individual is ready to make that transition at 10pm on the date of admission, or 17 hours later, what is the likelihood that Provider B will accept that admission if they cannot bill for services until the following day?  We do not believe the intent is to keep people in a service longer than is necessary; however, as written it appears that this might be the case at times.