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11/6/21  10:56 am
Commenter: Lorie Horton, Highlands Community Services

Appendix G Comments
 

Mobile Crisis Services - The provision of service should not require a referral from the Crisis Hotline. Nor should it be requirement to bill.  This is contrary to the Code of Virginia which requires law enforcement to directly notify the Community Service Board of the execution of an ECO.  For law enforcement to be required to communicate through a third party (Crisis Hotline) creates an unnecessary step, the potential for miscommunication, and delays the availability of transfer of custody at CIT Assessment Centers.  This could result in individuals and officers waiting in potentially unsafe situations for guidance/ response.  Based on DBHDS feedback if contact may occur following the service then the language should be revised.

Community Crisis Stabilization – The requirement for a crisis hotline referral as a condition for billing creates needless duplication of effort for both the hotline and providers when an individual is transitioning between levels of crisis care.  – Example any consumer served in 23-hour crisis observation would require a separate crisis hotline call to be referred for community crisis stabilization.  Based on DBHDS feedback if contact may occur following the service, then the language should be revised and allow for the initial hotline contact to follow the consumer through the episode of crisis care across services.

23 Hour Crisis Stabilization- The requirement that a psychiatric evaluation must be available at the time of admission should be clarified to only be required when assessed by the LMHP type to be necessary.  Not all consumers will require psychiatric evaluation and prescribing of medication during this service. In addition, due to workforce shortages there are not enough psychiatrist/ psychiatric nurse practitioners available to provide this service 24 hours per day.  

Also related to healthcare provider shortages, there is a significant shortage of RNs nationwide.  The allowance for use of a Licensed Practical Nurse is unhelpful because it requires an RN to be at the facility.  If nursing is a required component it should be on an as needed basis- available to respond to the location OR allow for LPN level nursing with access to an RN by phone for oversight/ supervision.  This requirement as written is cost prohibitive and cannot be accomplished by providers with a December 1, 2021 implementation date.  The earlier draft of the regulations did not require 24/7 RN staffing, including the draft regulations circulated in August 2021.

Residential Crisis Stabilization- Regulations require that an assessment, nursing assessment and psychiatric evaluation must occur on the “day” of admission.  As RCSU is a 24 -hour program, it is requested that the language to revised to allow the assessment to occur within 48 or 24 hours.  As written in creates needless timelines for the assessment process to be completed before midnight.  It does not allow time for individuals experiencing severe psychiatric symptoms or under the influence an opportunity to participate in the assessment process, thereby forcing the use of more restrictive and costly levels of care.

If nursing is a required component, it should be on an as needed basis- available to respond to the location OR allow for LPN level nursing with access to an RN by phone for oversight/ supervision.  This requirement as written is cost prohibitive and cannot be accomplished by providers with a December 1, 2021 implementation date.  Earlier draft of regulations did not require 24/7 RN staffing, including those draft regulations circulated by DMAS in August 2021.

The billing codes in this section identify that RCSU may bill under a temporary detention order. The language around involuntary individuals does not and is contradictory.

Assessment and CEPP – The assessment should be consistent with other assessment processes like the CNA and allow for the assessment tool used to be updated and revised as the individual transition to different levels of care without needlessly requiring the individual to repeat their information.  Ideally the assessment should also align with ARTS so two separate assessments are not required.

The CEPP is required for multiple services. The CEPP utilized by REACH is cumbersome and is a poor fit for acute, shorter term services such as 23-hour Crisis Stabilization. 

CommentID: 116707