App. G page 15 notes goal of Community Stabilization service to be stabilization for the individual within their community and to support the individual and natural support system during three particular circumstances. These circumstances include transitional step-down from a higher level of care if next level of care is identified but not immediately available and/or as a diversion from a higher level of care.
Seven days has most often not been a sufficient amount to meet goals and three days will certainly not be. If the goal is to stabilize within the community, I encourage further consideration of these proposed changes. The level of intensive therapeutic support and time needed to have opportunity to coordinate care for a stabilization service is not realistic to occur within these timeframes.
The parameters identified with community stabilization in Dec 2021 seemed to shift the service to reactive rather than preventative/responsive. The two of the above criteria can be considered a preventative to have this tool/resource to offer in effort to prevent a higher level or care or irreparable harm and seem to connect to the service description for community stabilization; however, the parameters proposed do not support true stabilization goal and instead seem to be barriers to both referrals to community stabilization and benefit from the service for individuals/families.
There is a significant value in the service and has been incredibly beneficial in our community. Please consider the barriers these parameters (specifically amount of time service can be involved, how the service is accessed) are adding to a much needed support, especially during a time that accessing longer term services is at a significantly longer wait time.
App G page 16- "The provider to engage with the crisis call center and data platform prior to initiating service."
There continues to be concerns regarding confidentiality related to information in the data platform.
There are assessment and planning questions in the platform in addition to need to complete the CEPP as well as documentation needs for agencies. Especially with the bringing in the platform, there continues to be more requirements added in regard to documentation. This information is important for various reasons; however, with just continuing to add, there seems to be redundancy which becomes overwhelming for individuals/families who are already in crisis and is a heavy lift for clinicians. This also speaks to issue with how quickly there is turnaround expected for requesting continued stay which again is additional documentation needed.
On page 18 regarding meeting medical necessity-noted is that a CSB same day access intake determines community stabilization need to prevent higher level of care and to link individual to appropriate community services. Please clarify- is there requirements of who community stabilization can accept referrals from providing determined to meet medical necessity (ie call center, same day ACCESS, emergency services)? Again, accessing this service has seemed to become more confusing and challenging impacting use of a valuable resource.
App G. page 24- regarding overlap of community behavioral health services. Please clarify what services this may include or if in general means ANY behavioral health services. What if client is in a service, such as outpatient therapy, and in need of more intensive support temporarily?
App G page 17- regarding services must be available 24 hours per day, 7 days per week in home, workplace or other setting convenient and appropriate for the individual.
This is not realistic. Workforce is already a challenge and this requirement would far exceed capabilities of the current workforce. We must care for our staff in effort to be able to provide quality care to our community.
