Please revise the definition of “psychiatric evaluation” to better match standard terminology wherein psychiatric evaluation is a type of assessment, completed by a provider with specific credentials, vs. the ongoing care of medication management services.

What will be the name of the DBHDS license required to provide Mobile Crisis Response services?  Page 10 states “crisis stabilization,” however our understanding is that the intent is to distinguish this service from Community Crisis Stabilization (page 19 states that Community Stabilization will require a DBHDS license for “Crisis Stabilization”).   

While Mobile Crisis Response services need to provide appropriate care and support, the service is not intended as one where “supervision” will be provided.  The broad system needs to be robust and flexible enough to allow Mobile Crisis Response teams to intervene with individuals in need without creating a bottleneck by expecting them to supervise individuals awaiting another service.

As written, Community Stabilization referrals are made from Mobile Crisis Responders or from inpatient settings.  This indicates there are no direct referrals to Community Stabilization – is that the intent?  Direct referral from a Regional Call Center or other resource provides an additional avenue to support individuals.

Regarding Residential Crisis Stabilization Units, while it’s understandable that most of the various services listed may not bill concurrently with this service, stating they can’t be concurrently authorized potentially implies that authorizations will have to be stopped and renewed.  This creates an administrative burden on both providers and DMAS/MCOs while interrupting the intended smooth flow of services; please rephrase.  In addition, services such as ACT inherently include a case management component, which is likely to be needed at this time and should be billable as it is in the best interest of individuals served.  The seven-day overlap is appreciated and important.

While we agree that seeking admission to RCSU should not be allowable as a means for individuals to avoid incarceration for existing charges, one intention of this service is to ensure that individuals in need of mental health services are routed correctly, vs. being incarcerated.  Please rephrase to reflect this focus on appropriate treatment and to decrease the criminalization of mental illness.

There are significant concerns that the funding for these services is not adequate to ensure that high caliber services, by qualified individuals, is able to be provided to all.  Please ensure reimbursement rates adequately reflect the expense of providing this type of service.

We request that DMAS work with all six contracted MCOs to ensure consistency regarding the durations of initial service authorizations.  Having to negotiate and monitor different timeframes across multiple MCOs detracts from time devoted to service delivery and supervision of these critical services.  Additionally, setting an expectation for the MCOs to ensure their fax machines accept submission is an important aspect of seamless service delivery.  Current experience such as a lack of confirmation of transmittal or rejected faxes has created inefficiencies and disruptions to service provision.

Please allow for greater latitude regarding the completion of the LOCUS “at the start of services” as there are instances in which direct intervention may help stabilize the situation more quickly than focusing on a structured assessment.  While assessment is certainly a critical aspect of service delivery, in a crisis, de-escalation should be the primary focus.

Ensure that requirements regarding Crisis Education and Prevention Plans are not overly constrictive or cumbersome and are reflective of current best practices and allowances.