Mobile Crisis Response, pg. 12

 "The provider must engage with the DBHDS crisis call center and crisis data platform prior to initiating services."

Currently providers enroll individuals in the data platform and obtain a reference number to accompany the MCO registration process. Does the change in language referenced here imply a change in this process? Establishing simple processes to initiate crisis services is essential in the provider's ability to respond rapidly and effectively. Providers of crisis services have established referral networks that currently work to divert individuals from higher levels of care. Adding additional steps to the referral process will delay response times and weaken positive service outcomes. Regulations should work to preserve a "no wrong door" approach.

Community Stabilization Medical Necessity Criteria pgs. 26-28

The proposed changes to the admission criteria exclude individuals who recently experienced a behavioral health crisis (within the past 24-72 hours) and who meet all of the medical necessity criteria except for discharging from a higher level of care. Arguably, these individuals are at high risk of needing a higher level of care, and community stabilization should be an appropriate service to adequately treat these individuals and to also divert from higher levels of treatment.

Please consider admission criteria to include:

1.) Individuals who recently experienced a Behavioral Health Crisis. (Recently may be defined as within the past 24-72 hours.)

2.) Documentation indicates evidence that the individual currently meets criteria for a primary diagnosis consistent with an International Statistical Classification of Diseases and Related Health Problems (ICD) diagnosis that correlates to a Diagnostic and Statistical Manual diagnosis in the most recent version of the manual; and

3.) The individual has demonstrated a level of acuity indicating that they are at risk for crisis-cycling or dangerous decompensation in functioning and additional support in the form of community stabilization is required to prevent an acute inpatient admission; and

4.) There is evidence that if immediate access to the intended referral service is not available, the individual is likely to go into crisis or experience a dangerous decompensation in functioning and thus community stabilization is necessary in order to maximize the chances of a successful transition to the intended service;

5.) A clinically appropriate and specific behavioral health service provider referral(s) has been identified and a plan for the timeline of transition from Community Stabilization to that

Community Stabilization, pg 27

I recommend omitting criteria iii., (a) The service that the individual needs and is recommended by a professional listed in item i. above or a professional coordinating the discharge plan from services listed in item ii. above is not currently available for immediate access;

Criteria iii. (b) and (c) achieve the same objective while simplifying the criteria.

Community Stabilization, pg. 35

Please consider authorizing a number of units to support assessment and initial planning activities within the first 24 hours, (which may span across two calendar days). This initial service funding should not be subject to a prior authorization process.

Given the proposed regulation changes from a registration process to a prior authorization process, it is critical that MCOs prioritize these reviews and responses. To avoid service disruptions or compromise to quality care, providers must be informed of authorization statuses within one calendar day.