Section: 8. Exclusions and Service Limitations

1.  The following are not reimbursable:

• How does the restriction around individual being present during documentation impact the practice of concurrent/collaborative documentation?

2.  Admission and Concurrent Services Limitations
   • “The CPST provider or affected provider or business of the CPST provider shall not provide Mobile Crisis Response, 23-hour Crisis Stabilization or Residential Crisis Stabilization to any individual receiving CPST”.  This will be a barrier to any Community Services Board’s ability to provide CPST services.
   • Just because an individual meets the admission criteria for one of the listed services does not mean that that service is available in the area and it limits individual choice of services/providers
   • Putting the authorization of additional behavioral health services in the hands of the MCOs to authorize or exclude based on participating in CPST services could limit access to needed sources such as psychiatry services, substance use support services, etc could be a barrier to clinically indicated care.  Allowing the MCOs that flexibility to make that decision could be unethical as they have a financial benefit as a result of that decision.
3. Other limitations
   • If the DBHDS licensed office location is a residential service/location, is the restriction to no more than one hour a week in that location applicable?