Mental Health Services, Appendix G:
Page 7: Critical feature of Mobile Crisis Response include: …. Zero Suicide/Suicide Safer Care principles;
Question: Will there be specific training or documentation requirements tied to these principles?
Page 8: Mobile Crisis Required Activities: The Locus will only be required in cases where the pre-admission assessment results in a referral away from the involuntary commitment process.
Observation: The domains described would be duplicative of the documentation already completed in the Pre-screening assessment.
Recommendation: Please consider removing the Locus as a requirement if a Prescreening Assessment is completed no matter the results of the assessment.
Page 8: Mobile Crisis; Page 17: Community Stabilization: Page 25: 23-Hour Crisis Stabilization; and Page 32: Residential Crisis Stabilization - Required Activities – “The Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements shall be required during the entire duration of the any crisis service.” If the intent is to mandate use of the DBHDS CEPP currently utilized by REACH, the document is duplicative of other assessment requirements already included in the draft.
Recommendation: Please consider also allowing the Prescreening Assessment be used and updated at each change of service type to address treatment goals instead of the CEPP.
Page 9: Mobile Crisis, Service Limitations: “Services may not be provided in a Psychiatric Residential Treatment Facilities, Therapeutic Group Homes, Inpatient Psychiatric or ARTS ASAM levels 3.1, 3.3, 3.5, 3.7, and 4.0 unless it is for the explicit purposes of pre-admission screening by a DBHDS certified pre-screener.”
Recommendation: For agencies that may have multiple levels of ASAM service provided within the same address this could become confusing. It is recognized that the service site may be the best option of provision of mobile crisis services. Please consider re-wording the statement to read. Mobile Crisis may only be provided in Psychiatric Residential Treatment Facilities, Therapeutic Group Homes, Inpatient Psychiatric or ARTS ASAM levels 3.1, 3.3, 3.5, 3.7, and 4.0 unless it is for the explicit purposes of pre-admission screening by a DBHDS certified pre-screener.
Page 10: Mobile Crisis – Staff Requirements – Team Composition #3
Observation: QMHP-E is not listed
Recommendation: Please consider including QMHPE
Page 12: Mobile Crisis Response, Admission Criteria: “1. The individual must be in an active behavioral health crisis that was unable to be resolved to the individual’s satisfaction by the Crisis Hotline phone triage process or other community interventions;”
Request: Please define Crisis Hotline phone triage process or provide clearer refence. Is this the regional call center/988, or the currently required 24/7 Board-specific emergency services access line?
How is this proposed to be tracked, measured, and monitored? Based upon each locality’s operationalization and crosswalk of the 911/988 response protocol, if a call occurs through 911 operators rather than 988 call centers for situations where co-response teams with law enforcement may be dispatched, there will be no record of any phone outreach/triage.
Recommendation: Due to the complexity of various methods of entry into the crisis system and the impossibility of verifying such contacts or other community interventions as a condition of admission, please consider modifying the criteria to the following:
1. The individual must be in an active behavioral health crisis that was unable to be resolved to the individual’s satisfaction by the Crisis Hotline phone triage process or other community interventions;”
Page 14: Mobile Crisis Response, Billing Requirements, #6: “If an individual has a service where crisis intervention is required, it is preferable that crisis intervention is provided by that service provider (example: Assertive Community Treatment), however, there may be instances where Mobile Crisis Response is more appropriate based on the individual’s needs.”
Recommendation: Please provide examples of “instances” where Mobile Crisis Response would be considered a more appropriate option and where the service provider’s crisis intervention would be a more appropriate option.
Page 16: Community Stabilization Required Activities: “A Locus, meeting DBHDS requirements is required for this service. The assessment must include the follow elements…”
Observation: By definition this service is part of a continuum of crisis services designed to cover the gap between either the earlier provision of Mobile Crisis services or step down from a higher level of care. In most cases, an assessment and treatment recommendations of the crisis episode would have already been completed to provide Community Stabilization. Completing a Locus would in many circumstances be duplicative documentation.
Recommendation: Please consider allowing a prescreening assessment or update completed by a Certified Prescreeners to be used instead of a Locus.
Page 19: Community Stabilization – Staff requirements, staff composition
Observation: Certified Prescreeners are not included. QMHP-E is not included in #1
Recommendation: Please consider including Certified Prescreeners as qualified to complete the assessment and level #2 and QMHP-E in level #1.
Page 20: Community Stabilization, Staff Requirements and Page 11, Mobile Crisis Response, Staff Requirements - “All Mobile Crisis Response/Community Stabilization staff must be in possession of a working communications device in order to provide care coordination, engage natural/family supports and link the individual to needed follow-up services.”
Observation: Current broad-band and cell phone coverage areas for many parts of the state are prohibitive of consistent cellular coverage to all operational communication devices that would meet the definition of “working”. Localities and providers have no control over this and no way to predict if a response/service location will allow for a working communications device until they arrive on scene. Especially for rural localities who experience broad cellular coverage gaps, we would recommend such a disclaimer be added to these sections.
Recommendation: Please consider adding “All Mobile Crisis Response/Community Stabilization staff must be in possession of a working communications device in order to provide care coordination, engage natural/family supports and link the individual to needed follow-up services as defined in the service description. Geographical areas with no available cellular or broadband coverage to allow utilization of a communications device does not constitute non-compliance with this requirement.”
Page 24 & 25: 23-hour Crisis Stabilization Required Activities: “This assessment should include a review of the Locus completed upon referral to this service and updated as need. If a prescreening assessment has been completed within 24-hours prior to admission the LMHP may review and update the prescreening assessment.”
Observation: Completing or updating both the LOCUS and prescreening document is duplicative.
Recommendation: Please consider allowing a Prescreening Assessment, completed by Certified Prescreeners, or updated to be used instead of completing a Locus and allowing Certified Prescreeners to conduct the assessment.
Page 26: 23-Hour Crisis Stabilization, Service Limitations: “Services may not be provided in Psychiatric Residential Treatment Facilities, Therapeutic Group Homes, Inpatient Psychiatric Units or ARTS ASAM levels 3.3, 3.5, 3.7, and 4.0.”
Observation: This seems in conflict with page 31 Residential Crisis Stabilization – Critical Features & Services Component which states “RCSUs may co-locate with 23-hour Crisis stabilization and Page 34 Provider Qualifications – If these units choose to provide ASAM 3.5 or 3.7 -WM services.
Recommendation: Please consider clarifying by adding to Page 26, 23-Hour Crisis Stabilization, Service Limitations: “Services may not be provided in Psychiatric Residential Treatment Facilities, Therapeutic Group Homes, Inpatient Psychiatric Units or ARTS ASAM levels 3.3, 3.5, 3.7, and 4.0. with the exception of programs that are licensed to provide both 23-hour Crisis Stabilization within Residential Crisis Stabilization and choose to provide ASAM 3.5 or 3.7 WM services as licensed by DBHDS.”
Page 27: 23-Hour Crisis Stabilization, Staff Requirements: “A licensed psychiatrist……must be available to the program 24/7 either in person or via synchronous audio-video telehealth to provide assessment, treatment recommendations and consultation meeting the licensing standards for residential crisis stabilization and medically monitored withdrawal services at ASAM levels 3.5 and 3.7.”
Recommendation: Please consider adding to the statement: A licensed psychiatrist……must be available to the program 24/7 either in person or via synchronous audio-video telehealth to provide assessment, treatment recommendations and consultation meeting the licensing standards for residential crisis stabilization and medically monitored withdrawal services at ASAM levels 3.5 and 3.7 if the program is licensed to provide these ASAM levels of service.”
Page 31: Residential Crisis Stabilization Required Activities: This assessment should include a review of the Locus completed upon referral to this service and updated as need. If a prescreening assessment has been completed within 24-hours prior to admission the LMHP may review and update the prescreening assessment.
Observation: Completing or updating both the LOCUS and prescreening document is duplicative.
Recommend: If a prescreening assessment can be used, please consider allowing the prescreening assessment, completed, or updated by Certified Prescreeners be used instead of completing and reviewing the Locus.
Thank you for your consideration of the above.