Miscellany for a Tuesday
April 26, 2022FIRST: More on the pending changes to Manual Chapter IV and Appendices E & G related to crisis services. We received this memo from DMAS:
DMAS’ Dr. Alyssa Ward, Behavioral Health Clinical Director, has recorded a short 25 minute video explaining the changes and the reasons why we needed to make these changes. You can find this video on our Youtube Channel here: https://youtu.be/EZX738A5IVg
This manual update includes the following changes:
- Chapter IV: Chapter IV includes general requirements for all mental health services as well as service specific provider requirements for Intensive In-Home (IIH), Therapeutic Day Treatment (TDT), Psychosocial Rehabilitation (PSR), Mental Health Skill-Building (MHSS) services, Mental Health Case Management (MHCM) and Treatment Foster Care-Case Management (TFC-CM). In addition to clarifications of existing language, the following changes were made:
- Language was added to indicate that providers shall discharge an individual if consent for treatment is withdrawn;
- Additions were made to the list of non-reimbursable activities for all mental health services;
- Language was added to IIH and MHSS to indicate that services must be provided on a one-to-one basis.
- Language was added to TDT and PSR to indicate that group delivery of the service is allowed and that providers shall not bill for time when the individual is not present at the program.
- Appendix E: Appendix E includes the level of care guidelines, medical necessity criteria, provider participation requirements, service authorization and billing guidance for Assertive Community Treatment (ACT). In addition to clarifications and a reorganization of existing language, the following changes were made:
- Language was added to clarify the role of the psychiatrist or psychiatric nurse practitioner and the time frames for the completion of the required psychiatric evaluation.
- An allowance was added for individuals to receive individual, group or family therapy outside of the ACT Team if the therapy involves a treatment modality benefiting the individual that is not available within the ACT Team.
- Language was added to clarify required documentation for continued stay authorization requests.
- Appendix G: Appendix G contains level of care guidelines, medical necessity criteria, provider participation requirements, service authorization and billing guidance for Mobile Crisis Response, Community Stabilization, 23-Hour Crisis Stabilization and Residential Crisis Stabilization Unit (RCSU) services. In addition to clarifications and a reorganization of existing language, the following changes were made:
- Added definitions for behavioral health crisis, crisis call center, skills restoration individual and telemedicine.
- Added a clarification on qualifying diagnoses.
- Added an allowance for assessments in Mobile Crisis to be completed through telemedicine by a LMHP, LMHP-R, LMHP-RP or LMHP-S.
- Added DBHDS data platform requirements
- Clarified that Mobile Crisis Response, Community Stabilization and 23-Hour Crisis Stabilization must be provided on a one-to-one basis with one staff or a team of staff providing services to one individual.
- Consolidated service limitation lists with the “Non-Reimbursable Activities for all Mental Health Services” in Chapter IV.
- Removed prohibition that if services are provided in a residential level of care, that the residential provider cannot also be the Mobile Crisis Response provider.
- Clarifications were made to the service authorization and billing section of Mobile Crisis Response.
- Changes have been made to the admission criteria, continued stay criteria, exclusions, service limitations, service authorization and billing requirements sections for Community Stabilization.
- Clarifications were made to the requirement for psychiatric evaluations in 23-Hour Crisis Stabilization and RCSU services.
- Changes were made to the admission criteria for 23-Hour Crisis Stabilization.
- Changes were made to the service requirements, service limitations and service authorization sections for RCSU.
In addition to the crisis appendix posted for review (including tracked changes), I have attached a version which highlights the language that has been updated.
SECOND: Conduent & DMAS confirmed yesterday that EDOCs will not be able to accept large documents until they have completed the upgrades that they are working on this week. While it has been promised by Friday, I wouldn’t count on it being available until Monday (and then remember there is a significant backlog of HCBS uploads to be completed which will likely slow down the process!)
THIRD: We know there is some conversation about the conflicts between the suggestions in proposed Guidance for steps needed to “modify” service plans if HCBS “rights” are involved and the DBHDS Regulations for Licensing and Human Rights — there appear to be no providers included in those discussions, so comments on the posted Guidance Document are critical! See this Post for more details!