On page 7 (Mobile Crisis Response) the requirement of a referral from the Crisis Hotline is required.  It is noted that collaboration and service coordinated with the Crisis Hotline is best practice for the crisis continuum.  However; the Crisis Hotline remains developmental and at the start of these regulations it is likely will not be fully capable of addressing this requirement and potentially limiting provider capacity to seek reimbursement for necessary services to promote community stabilization and decrease acute hospitalization.

Consider revised wording to read as coordination with a Regional Crisis Call Center, and potentially consider a grace period of 6-12 months to ensure that provider capacity and coordination with the developmental call centers does not negatively impact the availability of care to members.