We have recently received notice from Magellan that even though crisis intervention services can be provide for up to 30 days from the initial crisis intervention service that in addition to registering the initial crisis intervention service within 24 business hours, starting August 1, 2016, we need to re-register for crisis intervention services every 7 days. In trainings that have been provided by Magellan, we have been instructed that along with this re-certification we have to conduct a new or revised SSPI and a revised ISP.

It has been burdensome and counter-productive to providing quality clinical services to require a SSPI at the initial point of providing a crisis intervention service. There is much that a clinician needs to do when assessing and assisting an individual who is experiencing a behavioral health crisis that is clinically necessary. While some of the elements of the SSPI are important to know, there are many elements that are not necessary to gather in the midst of a crisis. More importantly, there is other information that is essential to know. For example, a glaring omission in the elements of the SSPI is the provision of a risk assessment regarding harm to self or others. If we are to avoid a hospitalization, yet safely manage risk, immediate clinical action is needed. Clinical documentation requirements should be kept to a minimum. It is my contention that the identified service specific elements of an SSPI are not service specific to the provision of quality crisis intervention services. Requiring another SSPI every 7 days compounds the issue.

Lastly, the regulations say that an ISP for crisis intervention services is not needed until the 4th crisis intervention session. I am therefore puzzled by the Magellan training where it was stated that a revised ISP has to be submitted every 7 days as well.

We are trying to utilize crisis intervention as a more appropriate, least restrictive, best practice alternative to hospitalization, especially given that our hospitals are struggling with census management for those who are more acutely in need. Additional requirements such as these present unnecessary barriers to stabilizing individuals in need and successfully diverting them from inpatient treatment.