With regard to Appendix G, I would like to comment on the use of the ISP/CEPP with regard to mobile crisis.  Not every mobile crisis contact requires treatment beyond the first contact because either the crisis is deesclated and no further treatment is needed, or the client needs a higher level of care and is then referred.  Therefore I still maintain that requiring an ISP for mobile crisis is an unnecessary burden placed upon treatment providers.  I can certainly see the utility in it for CSU services, but not for mobile crisis.

I would also like to see transportation addressed as a stand alone service for both TDO/ECOs and to facilitate a higher level of care in Mobile Crisis.  DBHDS only has one provider of alternate transport for TDOs/ECOs who refuses to expand or subcontract, and so I place the blame of not having the alternative transportation system we could have squarely on DMAS as they have refused to pay in cases of involuntary admissions, despite the laws having been in place for several years.  I think this could open an entirely new industry in the state and free up law enforcement as the laws have intended.

The requirement for Mobile Crisis to have an ISP seems clinically inappropriate given the brief nature of mobile crisis, often only one meeting/intervention. Mobile crisis includes assessment, crisis intervention (de-escalation), development of a safety plan, and care coordination (referral).  Mobile crisis is either coordinating with current outpatient providers or making referrals to outpatient providers, not providing any type of ongoing or even time limited therapeutic intervention. The requirements for an ISP (or crisis ISP) include measurable objectives, specific strategies, and frequency of services. These items do not clinically make sense in the context of what is essentially a one-time assessment/intervention and hand off to other services. Any individual would within a very short time frame either be doing a re-assessment of their ISP with current services providers (as would be expected when a crisis occurs) or developing a new ISP with new services, resulting in redundant work (developing an ISP with mobile crisis and then with another service or services) for the individual, which can be off putting and/or frustrating which could lead to less engagement/follow through with services.

Thank you for considering these comments.