Issues related to Mobile Crisis Response Level of Care:

1. LOCUS assessment tool.  It is good that we want to use a different instrument that is more concise and does not require the lengthy Comprehensive Needs Assessment to determine eligibility for the service.  However, there is concern about the training requirements to use this tool, as well as the ongoing training as there will be staff turnover.  The cost of training is an issue as well.  In addition, the LOCUS determines a level of care.  Who will provide this initial and ongoing training?  Will reimbursement still be available if the service is not available to address the level of care that is recommended as a result of the LOCUS?
2. Throughout the new Comprehensive Crisis Services manual it suggests that all referrals will come through the Crisis Hotline.  This does not seem logical.  It also suggests that a person must be in an active crisis that could not be resolved by the crisis hotline to be eligible for the service.  Not all crises are addressed on a hotline.  People in crisis show up at the emergency room, at the community services board, and in the community with other providers or with law enforcement.  All people in crisis do not call a crisis hotline…  therefore, boxing individuals in to being eligible for a service by calling a crisis hotline is not a logical expectation.
3. When a certified pre-screener completes an assessment and determines the individual does not meet the criteria for involuntary hospitalization (TDO) then the LOCUS must be completed.  This process seems like double work for the prescreener.  Both documents should not be required to be completed in order to receive reimbursement for the service that was provided.  Should be an either/or, not both. Preadmission screening document required for a TDO.  LOCUS required to determine other services to address the crisis.  Again, the training requirements for the LOCUS would influence this process as  pre-screeners would need to be certified to provide pre-admission screening as well as trained on LOCUS administration. 

Issues related to community stabilization level of care:

4. The draft for this service does not allow a certified preadmission screener to provide any community stabilization services. If a QMHP and registered peer can provide that service it seems reasonable to also allow a certified pre-screener to also have the ability to provide the service.  Certified pre-screeners have the education to assess and will also already have training in the LOCUS (according to this draft).  It does not make sense to exclude certified prescreeners as the staff eligible to be reimbursed for providing the community stabilization service.
5. The draft also states that the service must be available to schedule services 24/7.  Add certified pre-screener as eligible to provide the service providing a wider pool of staff to provide the service.