Under Critical Features and Service Components:

• Covered Services Include:
  • Crisis intervention:
    • FFT isn't a crisis intervention service; it is a crisis prevention service. Instead of providing crisis intervention, providers would be engaging in crisis and safety planning with families in an effort to prevent crises. This may be the difference between the ability to provide FFT, a family EBP model, concurrently with Intensive in home, a crisis driven in home approach

Under Medical Necessity Criteria

• #8 There is an order through juvenile justice for participation in community based treatment and the youth meets the other medical necessity criteria.
  • This appears to exclude youth who are not involved in the juvenile justice system who meet the other medical necessity criteria. Families are currently being provided FFT whose youth are not involved in the court system, but meet the medical necessity criteria as drafted.

Lastly, It is noted the Behavior change plan can substitute as the ISP. That may be functional if Medicaid is willing to wait 30 days for an ISP to be attached to a comprehensive needs assessment as the behavior change plan may not be completed until a provider is at most, 3 - 4 sessions in. To further explain, behavior change plans are completed prior to the start of the behavior change phase. Once that phase nears completion or is completed, a generalization phase plan is a completed, then generalization phase starts. The behavior change plan is no longer a focus, the generalization plan becomes the focus.