The Fairfax-Falls Church Community Services Board supports many of the issues with the Crisis Intervention changes other providers have posted. We wish to address the changes made to Crisis Intervention Services.

• While the intent of the changes may be to improve client care and promote efficiency, the oversight these regulations impose will do neither. The new 7 day re-registration requirement will have the effect of limiting services to a high-risk population by imposing additional  documentation burdens not just on clinical staff, but also on all support functions agency staff (Clinical, as well as IT, QA, UR, Billing & Reimbursement).

Qualified staff with contact with individuals in crisis are able to assess the length of time and number of visits it may take for an individual in crisis to stabilize.  That period may be just one or two visits in 7 days, but may take two or three weeks to get sufficient information and supports in place.  Containing the crisis is necessary to properly assess for the appropriate level of care.. The unreasonably short period of time a 7 day authorization allows invites inappropriate classification of an individual's treatment needs, with an unintended consequence that staff construct work-arounds that result in swift referrals to higher or lower levels of service that will be undermine effective service delivery, such as premature discharge, or hospitalizations that could have been avoided. 

• We also want to address the short timeline and inadequate training provided to implement these changes.  The inconsistent guidance Magellan offered providers (training slides and email communications silent on instruction provided in the webinar) created confusion that delayed providers work to get business processes and documentation sytems in place and staff trained.
• The CSB is dedicated to providing quality and person-centered services for individuals we serve.  We value the partnerships we've developed with DMAS and Magellan. We understand that appropriate oversight invites transparency, collaboration and higher quality services.  However, this effort to micro-manage the delivery of critical emergency services provided by qualified staff of trusted providers does not promote collaborative efforts or effective client services.

Thanks for the opportunity comment.