24/7 nursing services at all CSUs does not seem reasonable given the model of service delivery and the scarcity of the nursing resource in the Commonwealth. In particular smaller 6/8 bed units that service children and IDDD do not have a need for this level of care around the clock and use of medication and first aid trained staff with access to on call nursing or other emergent care are better aligned with the mission of a RCSU. A potential solution is to look at different levels of care to better differentiate the needs of the population being served and tracking the same through modifiers to the billing codes.
Psychiatric assessments still appear to play too prominent of a role in the RCSU regulations. While best practice for some, not necessary for all. The requirements to have access to physician services in Licensing is sufficient coverage to ensure that the appropriate resources are available to meet the needs of the individuals served in a person centered manner. Hard and fast timelines as spelled out will simply mean significantly more attention paid to auditing processes and exacerbate the fight with MCOs to retain funding for services that have been rendered and are not effective management of scarce resources available to meet an overwhelming need.
Use of a psychiatric evaluation completed within the last 24hours was a helpful inclusion, it may be worth considering evaluations completed in the last 72hours with documented review at admission.
The prohibition of billing a per diem for both a RCSU and 23hour Observation site when operated by the same entity is a deterrent to expansion of co-located facilities that operate within the Crisis Now Model and best practices in crisis care. If these two services were provided by different entities the billing would be supported per this draft of regulations and given they are separate services with separate staffing patterns billing of one should not preclude billing for the other.
