I find myself in a familiar place as I read over the newest changes to MHSS.  It appears that there is much thought surrounding some of the changes and that those changes will improve the delivery of services and pose no threat to those served.  Unfortunately, there are also proposed changes that will not improve the delivery of services and do pose a threat to those served. 

First, decreasing the time spent with a client each day but increasing the overall time allowed (now increasing units to 520 annually and 10 units weekly) appears to encourage dependency on the service and does not decrease the overall number of units allowed to bill for this service.  This change seems counterintuitive if the goal is to move clients through services and then step them down to a less intensive service. 

Secondly, there are many instances that require a clinician to spend 5 or more hours with a client in a single day.  A client may present with multiple emergent needs that, if unmet, may put the client into crisis.  In order to assist client with those needs, a clinician may be required to spend longer with the client.  Many clients who end up receiving psychiatric hospitalization due so with the support and encouragement of their clinician.  If a clinician accompanies the client to the emergency room for assessment, it is best practice for the clinician to remain with the client until the client is admitted to ensure safety and follow through. 

I do not believe it best practice to bill an excessive number of hours each day for MHSS.  However, there needs to be room for exceptions.  Within our company, we have found that 5-hour plus appointments happen rarely in urban areas and are more common in rural areas.  We also have evidence that many of those longer appointments are due to linking clients to other service providers to get clients’ needs met.  I would suggest a structure similar to the change made to Crisis Stabilization that states your agency may be flagged and audited if you exceed the recommended 2 units per day, although you are permitted to exceed the 2 units per day if necessary.