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Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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11/5/21  10:21 am
Commenter: Brooke Mitchell, Loudoun County MHSADS

Appendix G Comments

Appendix G requires that the hotline is called PRIOR to the initiation of crisis services.  This requirement is not feasible and has the potential to negatively impact the individual.  It is recommended that the agency consider a modification to “within one business day” rather than prior to initiation of crisis intervention.


Appendix G requires the providers “deploy in real-time to the location of the identified crisis.”  The Appendix is not clear as to reimbursements pertaining to transportation time.  We seek clarification regarding whether transportation time will be reimbursable.


Appendix G also requires a “referral from the Crisis Hotline” to bill for mobile crisis.  This requirement could potentially harm the individual by causing a delay in care when referrals are made directly by CSB staff or through law enforcement.  We ask that the agency consider modification of this requirement. 


According to Appendix G, “Submission of registrations [for Mobile Crisis Response reimbursement] must be within 1 business day of admission.”  The 1 business day requirement is shorter than the current time allowed to submit registration and creates an additional administrative burden for providers.  We ask that the agency consider maintaining current time frame.

CommentID: 116686