Community Stabilization:

To get to the point, there are a few areas of concern I would like to address on this platform that I hope can bring ideas for a fair compromise between DMAS and providers who are doing what is needed of them. So far, the comments all speak of the same importance and some really go in-depth with the same concerns I have as well. As a provider who is still gauging the changes made 3 months ago, I believe these changes are not in the best interest of the clients or providers. Burnout is real and so is experiencing a crisis. The changes do not logically make sense as to how this program can assist with the development of skills to navigate away from acute crisis and to prevent crisis-cycling with the reduced admission days.

To be frank, the initial 7 days sometimes is not enough. Truthfully, clients are just starting to build rapport while making some form of progress in the first seven days, then switching them to a lower level of care before services can be fully rendered has a high potential for a negative impact. Also with the reduced days, this leaves more continued stays to be submitted via an agency and depending on the speed of the MCOs can leave providers working on a case that is denied coverage, which is not helpful for providers and clients because this takes away developing support and entry into the mental health services clients are in need of. 

Also, in the video, which was helpful to pinpoint the changes, I interpreted these services to be from a higher level of care to a "warm handhold", but what about individuals who experience an acute crisis while receiving MHSS, PSR, IIH, or TDT? Is it expected for them to go into the hospital first, instead of utilizing the services created as "a diversion to a higher level of care"? How are providers to services individuals already placed into a lower level of care program, but happen to experience a true crisis that does not fully require inpatient treatment? There needs to be a way to focus on multiple aspects of crisis and people being services instead of common trends and making changes based on that. 

Crisis call center and data platform: is there a way a channel can be made for providers who may experience a client who is indeed crisis-cycling, so as providers doing their due diligence can take action to stop that? Gaining access to documents on a secured platform and tracking data focusing on helping the clients find and access services that can be put into place to help stop crisis-cycling and start providing yielding results of progress in their homes and communities. 

Housing: I completely understand housing not being reimbursable, but there are clients who are facing housing difficulties daily, and only giving providers 7 days, now proposed 3 days to help with stabilization in the community, does not help clients navigate one of the primary and main concerns they are faced with: temporary lodging. Another comment stated that housing is a big issue, which it is, but asking MCOs for housing resources is like asking them to explain this service and how they do billing. Some type of assistance somewhere is needed. 

I think a safe and fair middle ground for providers and DMAS (and other entities):

** Based on what is current

Initial Authorization is 15 days up to 6 hours a day, 1 continued stay sent no earlier than 24 hours before the 13th day in service, to look at additional time if needed. Continued stay meets requirements and medical necessity (CEPP is sent in with continued stay). The CNA (or other approved assessments) and initial authorization are submitted within 48 hours of meeting ( this gives providers time to contact crisis call centers and conduct a thorough assessment, including suicidal/homicidal screenings, which can be optional to submit with initial and continued stay (can show progress). From here, I believe this can lighten the burden placed on providers doing their jobs, and effectively help and assist clients through their crisis periods while maintaining a good way for DMAS and other licensing entities involved to monitor how this service is being used.