Mobile Crisis:

• Page 8 regarding the need for a CEPP.  Recommend the treatment plan be as brief and succinct as possible.  The template for the CEPP appears to be 9 pages.  This type of plan will be extremely difficult and time consuming to develop during the initial phases of working with a client in extreme crisis in their home

• Can certified pre-screeners do all of the parts of mobile crisis regardless of degree?

• Does the prescreening part fall under the 85% in the filed?

• Does mobile crisis include calling the  the 35+ hospital’s and coordinating to find bed dispositions?

23 Hour Observation:

• Page 25 refers to the LOCUS “completed at time of referral” being reviewed as part of the assessment to 23 hour.    Is the expectation that the LOCUS be completed by a LMHP or LMHP-E staff at the 23 hour program or by staff from other facilities, such as hospital emergency rooms, and does the LOCUS/review fulfill the assessment requirements as it does for mobile crisis?

Residential Crisis Stabilization:

• Page 37 regarding days covered by initial registration—strongly support the apparent change from the initial draft from 3 days to 5 days covered.
• Page 38 regarding ability to submit a registration for crisis stabilization after completion of Withdrawal Management services.  Strongly support the availability of residential crisis stabilization following withdrawal management since the majority of individuals coming in with substance use disorders also have co-occurring mental health disorders that need to be treated to insure stability in the community following discharge.
• Regarding current discussion at DBHDS for an additional assessment tool, in addition to the LOCUS and CEPP for residential crisis stabilization—strongly recommend that no additional assessment is needed.  Between the LOCUS and the full CEPP, all relevant assessment areas needed to provide treatment are covered.  It is essential that the amount of documentation for all services be as concise and efficient as possible to allow for the optimal amount of time to devote to treatment and not additional paperwork.
• Many CSUs use clinicians with credential of QMHP, and CSAC. In the draft proposal for Comprehensive Crisis Services for 23-hour Crisis Stabilization and Residential Crisis Stabilization levels of care lists the following under Staff Requirements. “Individual, group, and family therapy must be provided by a LMHP, LMHP-R, LMHP-RP, or LMHP-S.”

To that we recommend adding: “Collaborative therapeutic treatment may also be provided by a QMHP-A, QMHP-C, QMHP-E, CSAC, CSAC Supervisee, or CSAC-A, within their scope of practice, and under the supervision of a LMHP, LMHP-R, LMHP-RP, or LMHP-S.”

All Crisis Services:

• Regarding the need for a CEPP.  The goal of these crisis services is to transition to ongoing outpatient services.  At the intake for outpatient services, an ISP is required and the CEPP will no longer be needed.  It is recommended that a common treatment plan template be utilized for both crisis and ongoing outpatient services to allow for continuity of goals and objectives and provide a resource document of all needs, strengths, and services provided.