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

What will be the DBHDS license required to provide Mobile Crisis Response services?  Page 9 states “crisis stabilization,” however page 19 states that Community Stabilization will require a DBHDS license for “Crisis Stabilization” – will these both fall under the current non-residential crisis stabilization license?  Information provided by DBHDS on September 13, 2021 in their DBHDS Monthly Key Updates indicates that Mobile Crisis Response “will replace the current crisis intervention definition.” 

While the Crisis Hotline is critical referral source, direct referrals to Mobile Crisis Response should also be allowed, to allow for faster response and decrease the risk of bottlenecks at the Crisis Hotline.  Similarly, although page 15 states that “a referral from the Crisis Hotline is required” for Community Stabilization, page 14 describes the services as being one to support individual at any one of three points in the array of crisis services.  How will the referral process work?  More specifically, will providers of Mobile Crisis Response need to contact the Crisis Hotline to refer someone to Community Stabilization for the time between the initial service and entry to an established follow up?  Will providers of higher level of care services need to contact the Crisis Hotline to refer individuals for a transitional step-down?  This would seem to be inefficient and detracts from the role of the Crisis Hotline.

Thank you for adjusting the exclusion criteria to specify the exclusion of individuals who do not meet criteria and are attempting to use this solely as an alternative to incarceration.

Please postpone the additional requirement for Mobile Crisis Response and Community Stabilization to be provided 24 hours per day.  While this is our ideal, shared goal, notification of this requirement in mid-October does not provide adequate time to seek out and hire already scare resource for a December 1, 2021 implementation date. 

For Residential Crisis Stabilization, stating that staff must be available at the time of admission to provide a psychiatric evaluation and that psychiatric evaluations must occur on the day of admission is prohibitive.  Revise “on the day of” to a specified timeframe such as 24 hours, which affords services to be provided in a reasonable timeframe for individuals admitted at either 10:00 a.m. or at 10:00 p.m.  

Should the statement about a seven day overlap with other behavioral health services (p. 34) be an independent statement, vs. a bullet point?  As written, it is unclear if that is excluded from concurrent billing or an allowance that recognizes the importance of continuity of care.

Please postpone the additional requirement for an RN to be present on the unit at an RCSU 24/7 considering the current staff shortages faced by all health care providers.  Notification of this requirement in mid-October does not provide adequate time to seek out and hire an already scare resource for a December 1, 2021 implementation date.  Similarly, additional time is needed to allow currently employed Peer Recovery Specialists to complete the steps needed to become Registered in their field.

Previously articulated, 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 is magnified by the increased staffing requirements.  Ensure reimbursement rates adequately reflect the expense of providing this type of service.  Ensure the billing rules allow for a smooth flow and appropriate remuneration for providers of each service.  Similarly, to say that Residential Crisis Stabilization services are not billable on the day of discharge discounts the importance of services that are a part of the discharge process and their importance in successful transition.

Previously, there had been indications that the LOCUS would be implemented with these services suggesting as a focused and shorter means of assessing clinical status and needs.  This revision returned to use of the lengthy Comprehensive Needs Assessment or an unspecified DBHDS approved assessment.  Please ensure expectations include an assessment option that meets the needs without placing undue stress on individuals who crisis, who are often unable to participate in a lengthy assessment process.  In addition, there is a need for latitude in completing an assessment “at the start of services, “as there are instances in which direct intervention may help stabilize the situation more quickly than diving into a structured assessment.  While assessment is a critical aspect of service delivery, in a crisis, de-escalation should be the primary focus.

We again 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.

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