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Department of Medical Assistance Services
 
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Board of Medical Assistance Services
 
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11/4/21  1:20 pm
Commenter: Rebekah Brubaker, HRCSB

RCSUs
 

Residential Crisis Stabilization Units

My primary concerns are related to the requirements of 24/7 RN coverage and having a psychiatric evaluation done at the time of admissions.  It seems that it would be appropriate to allow RCSUs to be staffed by LPNs without RNs on-site if the LPNs have access to RN, NP, MD etc. for guidance/work direction etc. If this adjustment is not approved and updated in the manual, I believe that several RCSUs will not be able to operate and thus compounding the issue bed shortages and alternative placements to inpatient hospitalizations. I am also advocating for the psychiatric evaluation to be done within 24-48 hrs of admission and not "at the time" of the admission, as clients are already undergoing several assessments/screenings at the time of entry into the program.  I have also included several specific areas that it would be helpful for language/expectations to be updated or clarified.

  • Pg. 32 (First bullet): “A psychiatric evaluation by a psychiatrist, nurse practitioner or physician assistant must be available at the time of admission into the service.”
    • Consider revising the statement "at the time of admission" to allow for a 24-hour period or longer depending on if they are stepping down from a higher level of care. It does not seem client-centered or trauma informed to have clients sit through multiple assessments at the time of admissions if there is recent information that can be reutilized.
  • Pg. 32 (Third bullet): “The Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements is required for this service and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S.”
    • What are DBHDS required components for the CEPP? It is essential for us to have that information prior to 12/1/2021 so that we can create the necessary forms/documentation/processes to incorporate this new requirement.
  • Pg. 35 (Staff Requirements, fifth paragraph): “Nursing services shall be provided by a RN or a LPN working directly under an RN who is present on the unit.”
    • This is a change from previous, as on-site nursing was not required for Crisis Stabilization, only Withdrawal Management. Now, not only will nursing coverage be required 24/7, but a RN must be present at all times. This will present significant challenges for recruitment and staffing. Recommend Staff Requirements to say “Nursing services shall be provided by a RN or a LPN working directly under an RN who is either present on the unit or available by telephone.”
  • Pg. 33 (First bullet): “On the day of admission, at a minimum, RCSU providers must provide assessment, psychiatric evaluation and a nursing assessment.”
    • Currently, psychiatric evaluation is required to be completed within 24 hours, so may not be done on the day of admission. Evening admissions will often not be able to complete these three assessments before midnight. Recommend changing the time frame from “On the day of admission…” to “Within 24 hours of admission…” or even longer if the individual is setting down from a higher level of care.
  • Pg. 32 (3rd bullet)

“The Crisis Education and Prevention Plan (CEPP) meeting DBHDS requirements is required for this service and must be current. The CEPP process should be collaborative but must be directed and authorized by a LMHP, LMHP-R, LMHP-RP or LMHP-S.” and

Pg. 36 (first paragraph)

“Treatment Planning must be provided by an LMHP, LMHP-R, LMHP-RP, LMHP-S; QMHP-A, QMHP-C, QMHP-E, CSAC* or CSAC Supervisee*.”

  • Does the CEPP replace the Treatment Plan or is it in addition to it? Both are mentioned in these sections, and the staff who are qualified to complete them require different credentials. Recommend to clarify if the CEPP replaces the Treatment Plan or is in addition to it, and confirm the credentials of the staff who completes it.

 

CommentID: 116620