Recommend “Telemedicine” be replaced by “Telehealth”, or, specifically, include audio-only as an option for behavioral healthcare services. Lower-income and rural clients do not often have reliable video or internet capabilities. Audio only for example could be allowable for some services if an effort to reduce barriers, increase access. Especially important early in treatment for crisis services and case management and when technical issues prevent video.
Recommend adding Telehealth option for coverage for:
Assessment-More specifically, Mental Health and Substance Use comprehensive behavioral health assessment. Will allow quicker access to care and reduce transportation barriers.
Outpatient Crisis Stabilization- will allow for more client choice, access to clients when short-term barriers arise
Mobile Crisis- Recommend adding this as Mobile Crisis Medicaid service option will begin December 1st through project BRAVO
Page 11: Concern with the wording of two elements listed as requirements under Care Coordination Requirements of Mental Health Providers
Actively collaborating with all internal and external service providers to achieve open communication and integration of all needed services; Concern as “open communication and integration of all needed services” is broad and not well defined. Additionally, if the provider has made attempts at collaboration, but the other provider won’t, the trying provider is not meeting expectations. It appears to remove individuals’ choice for what gets communicated.
Coordinating all services and supports, including all active treating service providers and the individual’s family members and significant others involved in the individual’s life. The inclusion of the word all active services and supports and treating service providers is a concern. This is very broad and implies a dependency on providers to coordinate activities, rather than assuring individual choice and promoting independence.
