Under the proposed provider manual, will individuals no longer be able to go directly to a private-sector provider to access crisis stabilization?
Currently, those with a primary substance abuse diagnosis are not able to receive the Crisis Stabilization service. Is this changing with the new service? If a provider is not licensed for substance abuse services, can they still provide Community Stabilization?
When will the DBHDS requirements regarding the change to crisis services be available? (LOCUS, CEEP, etc.)
For those moving to Community Stabilization from Crisis Stabilization – other than compliance with assessments and forms, what do providers need to do?
Can portions of Community Stabilization be done through group? Group was previously allowed as a component of Crisis Stabilization Services, but it is not listed as an allowable activity in the new manual.
Specific recommendations/questions/concerns
Page 6, 4th bullet
Clarify -- What is the step-down service for crisis? For adults without SMI or a prior hospitalization, what would service would be available? They would not qualify for ARTS or MHSS and OP would be more appropriate as a second step-down service.
Page 6, 6th bullet – Important that MCOs don’t interpret “ideally” to mean a two-person team is required.
Ensure language notes that “ideally” doesn’t equate to “required.”
Ensure a licensed person be able to participate remotely.
Page 7, 1st paragraph –. There is concern that law enforcement may not respond if the hotline triage does not indicate the need for a law enforcement presence but then the provider on the scene does think it’s needed. Need flexibility here.
Important to ensure a provider can request an escort if they believe it’s needed
Page 7, first bullet, page 15, Critical features, 1st bullet
Clarify -- What are “Zero Suicide/Suicide Safer” principles and how should they be integrated into the service? Will a training on this be provided prior to December 1, 2021?
Page 7, 10th bullet – How should providers “coordinate with the Crisis Hotline Service?”
More detail on what this means should be provided.
Page 8, Required activities, 1st bullet, page 16, Required activities, – Is use of the LOCUS assessment required or is it an option?
Clarify the following -- What are DBHDS requirements related to LOCUS? Will training on this be provided prior to December 1, 2021?
Page 10, 19, 26, 34, Provider qualifications
Clarify -- What is the DBHDS required training for this service?
Page 10, 19, Provider qualifications
Clarify the following -- Should providers be working now to secure MOUs now, so they are in place by December 1? Is a list available with regional crisis hub contacts? What is DBHDS’s role in this?
Clarify if providers can provide only one level in the crisis continuum as long as they have MOUs with the hubs.
Regulations state that there will be an MOU with the hub “via DBHDS”. What is the process for this? Providers are concerned as we are just 60 days out from this transition.
Allow a QMHP provide health literacy counseling. It’s not clear why would a licensed person be needed for this?
Page 12, #1
This appears to prohibit someone from accessing support without going through the crisis hotline. This is inconsistent with the “no wrong door” approach. How will this be reported to the MCOs?
Page 12, #3 – Criteria is not “trauma-informed.” Does not allow the service to be available to an individual who may have witnessed or experienced a traumatic event but has not yet exhibited symptoms. Service is only available based on a person’s behavior, not their experience with trauma.
Change language so person who experiences trauma is eligible.
Page 13, Service authorization – Concerns about how quickly MCOs are responding to service authorization requests. Providers indicate this turn-around time is not happening today, sharing that it could take days for an MCO to respond to the initial request. A lot can happen when a person is in crisis. With this, providers assume all risks related to the costs to deliver service.
Address turn-around issues.
Page 13, Billing requirements, #3
Clarify that QMHPs can do some of this work on their own, including care coordination by phone and other interventions.
Page 13
Clarify if mobile crisis or hospitalization required to receive Crisis Stabilization?
If so, this is seen as a barrier to receive this service. There is concern that the very restrictive language may push people to mobile crisis or a higher level of care than needed so they can access this service.
Language included on page 20 (medical necessity criteria) is recommended here.
Page 14, 15, 20 – Concerns with Community Crisis Stabilization due to the inconsistency in service definition and eligibility criteria with regard to how an individual may enter crisis stabilization services.
On page 14, it is indicated that the service is "following contact with an initial crisis response service." This could be seen as prescriptive by MCOs such that crisis stabilization may not be rendered unless the individual came directly out of a mobile crisis program within the past 72 hours.
A paragraph later (page 15), it is indicated that the service is to occur either after mobile crisis or as a step down from a higher level of care. These two statements are conflictual and MCOs will go with the more restrictive definition when trying to deny a service.
Later in the medical necessity criteria section (age 20), #1 states that the service may be provided after a behavioral health crisis. This is more flexible and not restrictive as to the way in which an individual comes into services.
Provide language that is more clear around the eligibility/admission to services.
So long as the language remains on page 14, MCOs can effectively use this criteria as a way to deny services any time the individual did not enter services through mobile crisis.
If the service is truly meant to be "an alternative to or diversion from inpatient hospitalization, residential crisis stabilization or more intensive level of care," then additional points of entry are needed in addition to mobile crisis and hospitalization.
Page 15 – “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.”
Clarify if this means on-call or just able to meet the client where they are? Ready to run out or just to discuss and schedule next visit?
Page 16 -- Peer involvement in Crisis Services
Clarify if peers involved in community crisis services have to be registered as a peer or can they just have gone through the training? Should providers bill PRS and Community Stabilization at different times in the same day? Does this mean providers need to have a PRS on the team and bill Community Stabilization?
Page 17, Service limitations
Clarify -- Is it OK to provide this service with other services for up to seven days? Can the service be provided for longer than seven days so long as no other service is being provided?
Page 18 – Draft states that trips to libraries are not allowed.
Clarify whether this could be allowed in cases where clients and QMHPs are using a library as a means to submit applications/wi-fi capability based on client's circumstances.
Page 20, Medical necessity criteria – Providers appreciate that hospitalization and/or use of mobile crisis is required to receive Crisis Stabilization.
Recommend this language be included on page 13.
Page 21, Exclusion criteria, #4
Clarify that an individual will not be excluded if services aren’t available in the 72 hours. Could this force a three-day gap between crisis services and a step-down service?
Clarify -- What is a Crisis Education Prevention Plan (CEPP)? How and where is this defined? Is a comprehensive ISP required? Is crisis excluded from CNAs? Does this mirror REACH, which is being used by the CSBs? Do the plans follow the person? If so, how does this work when multiple providers are involved? How are the plans updated? Are multiple assessments for each service still necessary?
Page 22, Service authorization, 1st paragraph –
Clarify whether the service need to be provided over seven days or can the units be used in a shorter period of time if appropriate?
Page 22, Service authorization, 3rd paragraph
Does this intend to read “224 units?”
Page 22, Service authorizations, 3rd paragraph
Clarify whether this be standard across all MCOs? Will they be able to authorize less?
Page 23, 24, Critical features, 1st paragraph
Clarify how a “community-based facility” is defined?
Page 26, 2nd paragraph, page 33, 2nd paragraph
Clarify if a “brick and mortar” site is the same as a “community-based facility.” If not, how is this defined? “Bricks and mortar” terminology may not be appropriate if considered literally.
