Concerning the proposed regulation requiring an authorization for Crisis Stabilization:

• Currently, the timeframe on receiving an approval for other services is anywhere from 2-5 days.  Considering that a client is in a crisis situation when they come into this service, it does not seem feasible to wait for an authorization to be approved to begin services.  An authorization requires a large amount of paperwork and this would further delay the beginning of actual services.
• If the intention is for providers to begin services without the approval, are providers guaranteed payment if the authorization is eventually denied?
• Delays in the beginning of the provision of these services could lead to clients seeking more expensive and intrusive higher levels of care.     

Concerning the proposed regulations which states that LMHP, LMHP- Supervisee, or LMHP- resident may complete, sign and date an ISP:

• In order for providers to have an LMHP/LMHP-like staff member to complete ISP’s, they need to hire staff.
  • In many parts of the state, there is a severe shortage of licensed or licensed eligible individuals to fill these positions which will mean that MHSS providers will not be able to fill the positions or stay in business.  Those licensed or licensed eligible who are available are not apt to take jobs such as these because they are paperwork intensive and they want to work with people, not just fill out papers.
  • These individuals are in high demand and will require higher salaries than the individuals who currently complete this level of paperwork which will be a financial hardship on businesses providing MHSS.
  • The work that would be required of these positions does not meet the requirement for hours toward licensure and as such do not make these jobs attractive to licensed eligible individuals, making it even more difficult to find staff to fill these roles.
• This approach to writing the ISP’s seems contrary to current trends.
  • The definition, scope of service and intent of MHSS has been modified to the point that regulatory bodies state that a QMHPP can provide the service, implying that the service is less intensive than others, yet it now requires and LMHP to write the ISP.  
  • These ISP’s will be written by staff who have very little contact with the client.