1. Comment period closes 9/29/2021

If the comment period doesn’t close until 09/29/2021 then there will only be a matter of weeks between the release of the final manual and implementation.  This is especially concerning considering the staffing crisis that mental health system in Virginia is experiencing.

2. Community Stabilization services are short-term and designed to support an individual and their natural support system following contact with an initial crisis response service. The draft also states, “The goal of Community Stabilization services is to continue to stabilize the individual within their community and support the individual and/or support system during the period between either 1) an initial Mobile Crisis Response and entry in to an established follow-up service at the appropriate level of care or 2) transitional step-down from a higher level of care if the next level of care service is identified but not immediately available for access.

The enhancement assumes that a mobile crisis team is in place and is unclear as to whether we can only provide services following mobile crisis response or step-down from hospital. For example, clarification is needed on whether a client can walk-in and be directly referred to Emergency Services or is required to be first be served by mobile crisis prior to referring to community crisis stabilization. Horizon receives numerous referrals directly from schools, community partners, group homes, PCP’s, and hospital mental health/ER

3. Providers deliver community stabilization services in an individual’s natural environment

 The enhancement appears to essentially eliminate or limit milieu work if services in the person’s natural environment are not feasible. Traditionally we take clients out of the problematic environment, at least initially, to stabilize them.  Once the client has stabilized we re-introduce them to the natural environment. 

4. Community Stabilization teams must be available to provide services to any individual in their home, workplace, or other convenient and appropriate setting and must be able to schedule appropriate services 24 hours per day, 7 days per week.

The enhancement assumes that a mobile crisis team is in place and prepared to serve any individual in multiple settings. Horizon ACS currently licensed for 4-21 years of age. We need clarification whether the enhancement require expansion to serve other age groups. Also, does this expand to primary ID and SUD clients? For example, is there a requirements to provide an appointment at any time (such as a client calling at 2:00 a.m. and asking for an appointment) or that a client must be able to have a session at 2:00 a.m.?

5. Assessment and screening, including explicit screening for suicidal or homicidal ideation;

Will the department be providing a preferred screening for homicidal ideation?  Or does each CSB need to find their own?

6. At the start of services, a LMHP, LMHP-R, LMHP-RP, LMHP-S must conduct an assessment to determine the individual’s appropriateness for the service. This assessment must be done in-person or through a telehealth assisted assessment. A Level of Care Utilization System (LOCUS) assessment can be used to meet this requirement if conducted by a LMHP, LMHP-R, LMHP-RP, or LMHP-S.

Will the department be providing training and other resources such as funding for the LOCUS?

7. The Crisis Education and Prevention Plan (CEPP) is required for Community Stabilization. It must meet DBHDS requirements, is required during the entire duration of any crisis service, and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S.

8. If an individual is transitioning between crisis services, the provider may review and update an existing CEPP in accordance with DBHDS guidelines.

Does the enhancement include plans for a regional process to get the CEPP to the CSB providing stabilization services (if that CSB does not provide the mobile crisis response)?

9. Community Stabilization may not be billed concurrently beyond a seven day overlap with any other CMHRS, EBH or ARTS service.

The restriction appears to exclude an understanding that Case management is a CMHRS service that is typically compatible with a crisis response services as an essential “non-crisis service” that provides linking to, and coordinating with concurrent crisis and post-crisis services.

10. Positive comments for enhancement

Medical necessity criteria is improved and easier to write

Flexibility for creating different treatment teams with various credential levels is helpful