There is conflicting information about proposed changes for Crisis Intervention services regulations provided through the Regulatory Town Hall document and the training/responses provided by Magellan.

1.       Magellan has advised that a Service-Specific Provider Intake (SSPI) and Crisis Intervention Registration will be required at initiation of service. In addition, the Crisis Intervention Registration will be approved for a maximum of 7 days at a time and a new Registration and new SSPI will be required for continued registration past 7 days.
   •         Nowhere in the proposed regulations does it indicate that a Crisis Intervention Registration will last for only 7 days and at the end of 7 days, a new SSPI will need to be completed for each additional 7-day registration approval. Magellan has advised that the 7-day registration is based on a business rule that is being instituted in order to meet contract requirements.
   •         However, regulations indicate that short-term Crisis Counseling can be provided under Crisis Intervention for a period of up to 30 days from the date of the first face-to-face contact.
   •         Furthermore Magellan has provided guidance over the past year or longer indicating that the SSPI is consider “current” for up to 30 days from the time it was completed.  Requiring that a new SSPI be completed by an LMHP, LMHP-R, LMHP-RP, LMHP-S, or Certified Prescreener and a new registration be submitted every 7 days creates burdensome assessment and documentation obligations for the provider; in addition, having to participate in weekly assessments that are primarily historical in nature may cause undue distress for individuals needing the service.
   •         Finally, the SSPI should include documentation of the anticipated duration of the need for the Crisis Counseling service which could indicate the length of time the registration is needed, up to 30 days.
2.       Regulations define the Individual Service Plan (ISP) as being driven by the needs identified in the SSPI, but that an ISP for Crisis Intervention must only be created by the fourth face-to-face contact with the individual. If that is the case, it would make more sense to complete the initial SSPI just prior or at the fourth face-to-face contact in order to reflect the most up-to-date needs as identified with the client during that visit.

 Requiring a new registration and SSPI every 7 days is likely to result in limiting, or even preventing, access to crisis services for individuals who require and would benefit from the service and could lead to utilization of services in a more restrictive setting such as residential or inpatient.