Horizon wishes to express concerns in regards to the proposed changes to the Appendix G draft. The proposed regulations would change the initial registration period from 7 days to 3 days for community crisis stabilization. The regulations state that within admission to the service the client must have some form of comprehensive assessment, a CEPP must be established or revised, and an ISP to address immediate safety concerns must be established per DBHDS requirements. In addition there is an expectation that discharge planning start immediately and that care coordination be provided throughout the entire episode. Also rapport building and the actual crisis interventions services. All of these components are essential to stabilizing an individual and only allowing an initial 3 days of services and a total of 12 hours will not be realistic to address most clients in crisis. Particularly those coming into services with limited resources. In addition having to do more frequent initial service authorizations create an administrative burden for both clinical and reimbursement staff.
In addition to the concerns about the change from 7 days to 3 days there is concern about the different requirements for client’s that have received crisis stabilization services within the past 30 days. This change places a burden on the provider to try to get a confirmation of whether or not the client received services within the last 30 days either from the client (who by nature of the crisis may not know when they had services), contact other services providers for confirmation, or attempting to contact the MCO. We are concerned about being able to get this confirmation in real time while the client is in an active state of crisis and needs immediate stabilization. The provider for the crisis services may have to choose between risking loss of revenue and delaying services until the MCO has approved the service auth. An example is attempting to start services on a Friday or a holiday.
Finally there is a concern about the first requirement under Community Stabilization Medical Necessity Criteria. This criteria indicates that a client must be stepping down from an acute level of care or group home setting (1.a.), CSB SDA recommendation by and LMHP type (1.b.) or referred directly from the crisis call center (1.c.). The concern is that clients already in an established level of care (such as case management) can only access this service if they utilize the call center or have been through a higher level of care. How does this address clients that may not want to contact the call center but meet medical necessity for community stabilization services? In addition it is not clear if prescreeners can directly refer clients to community stabilization services.
Some clarifications that are requested include the following: