Section: 8. Exclusions and Service Limitations

1.  The following are not reimbursable:

• How does the restriction around individual being present during documentation impact the practice of concurrent/collaborative documentation?

2.  Admission and Concurrent Services Limitations
   • “The CPST provider or affected provider or business of the CPST provider shall not provide Mobile Crisis Response, 23-hour Crisis Stabilization or Residential Crisis Stabilization to any individual receiving CPST”.  This will be a barrier to any Community Services Board’s ability to provide CPST services. 
   • Just because an individual meets the admission criteria for one of the listed services does not mean that that service is available in the area and it limits individual choice of services/providers .  Although this wording was slightly adjusted, we ask DMAS to consider removing this restriction.
   • Putting the authorization of additional behavioral health services in the hands of the MCOs to authorize or exclude based on participating in CPST services could limit access to needed sources such as psychiatry services, substance use support services, etc could be a barrier to clinically indicated care.  Allowing the MCOs that flexibility to make that decision could be unethical as they have a financial benefit as a result of that decision.   

Section: 9. Service Authorization

• The ability to MCOs to have the power to recommend a “more clinically appropriate service” based on their review is not appropriate.  At this point, there have been many requirements for the individual and treatment team to explore all options.  The MCO has a vested financial interest in this decision and many of the service authorization staff are not licensed providers qualified to make or override clinical appropriateness decisions.