Virginia Regulatory Town Hall
Agency
Department of Medical Assistance Services
 
Board
Board of Medical Assistance Services
 
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11/3/21  9:44 am
Commenter: Shenee McCray, RBHA

Comprehensive Crisis Services
 

Mobile Crisis Response

The draft manual indicates that a referral from the Crisis Hotline is required.  It is recommended that this requirement be removed as it eliminates the notion of “no wrong door”.  Many crisis referrals come from many places such as the hospital ED, schools, emergency services, etc.  This requirement would significantly increase the call volume for the regional call centers unnecessarily so.  This requirement would also add another step for the person in crisis or the referring entity.

On page 10, the 7th bullet indicates that “Peer Recovery Support Services must be provided by a Registered Peer Recovery Specialist”.  What is the timeframe in which the peer should become registered?

 

Community Stabilization

The draft manual indicates that a referral from the Crisis Hotline is required.  It is recommended that this requirement be removed as it eliminates the notion of “no wrong door”.  Many crisis referrals come from many places such as the hospital ED, schools, emergency services, etc.  This requirement would significantly increase the call volume for the regional call centers unnecessarily so.  This requirement would also add another step for the person in crisis or the referring entity.

On page 16, the 4th bullet indicates that CEPPs must be reviewed and updated as an individual moves between crisis services (Mobile Crisis Response, Community Stabilization, Residential Crisis Stabilization unit, 23-hour Crisis Stabilization) according to DBHDS requirements. Please provide clarity as the CEPP is not required for Mobile Crisis Response (and shouldn’t be required) however it is listed here as if it is required.

 

Residential Crisis Stabilization

On page 32, the first bullet indicates that “a psychiatric evaluation by a psychiatrist, nurse practitioner or physician assistant must be available at the time of admission into the service”  It is recommended that a psychiatric evaluation is be required within 24-48 hours of admission.  Many programs do not have a prescriber available at the time of admission.

On page 39, #4 under Residential Crisis Stabilization Billing Requirements, it says “If a provider is licensed for both RCSU and for the provision of ASAM Level3.5 and/or 3.7 – WM, and an individual is admitted to the RCSU for withdrawal management services, the provider should bill for the Addiction and Recovery Treatment Services until withdrawal management is no longer needed.  At that time they may submit a registration for RCSU services.”  It is recommended withdrawal management be allowed as an option for this service as long as there is sufficient documentation to support withdrawal management services.

CommentID: 116610