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Federal guidance provides clarity on the opportunity to include mobile crisis intervention services

HMA Federal Policy Principal Andrea Maresca, Managing Principal Gina Eckart, Principal John Volpe, and Senior Consultant Suzanne Rabideau weigh in on the recent changes and HMA experience in crisis intervention services.

Recent guidance from the Centers for Medicare & Medicaid Services (CMS) outlines the scope of, and payments for, qualifying community-based mobile crisis intervention services as well as the pathway for states to access higher federal Medicaid matching rates for select IT services, program administration and program maintenance costs. The guidance and payments are authorized by the American Rescue Plan Act (ARPA), which established a new opportunity for state Medicaid programs to provide these services for up to five years (April 1, 2022-March 31, 2027).

Crisis intervention services and solutions are designed to provide rapid response to individuals in need wherever they are, including at home, work, school, or anywhere else in the community. Mobile crisis providers are trained to use effective engagement and culturally responsive approaches to support a resolution of the crisis. This includes referral and linkage to ongoing support to help the individual remain in the community, preventing avoidable inpatient or justice involvement, often resulting in cost savings.

Importantly, the new Medicaid option also provides states with an 85% federal match rate for these crisis services for the first 12 fiscal quarters of the timeframe. In addition, certain administrative costs and IT system costs are eligible for the higher matching funds, for example, operating state crisis access lines and dispatching mobile crisis teams to assist Medicaid beneficiaries.

The guidance identifies core components and services that must be a part of the crisis intervention teams. However, states have significant flexibility to design the overall model – including use of fee-for-service and managed care programs – as well as the makeup of the provider teams and use of telehealth to provide certain services. 

As states begin developing or building upon their current crisis intervention models, the guidance provides long-awaited details on the specific requirements Medicaid programs must meet to receive the higher federal matching rate for reimbursement of crisis services. Additionally, CMS discusses the maintenance of effort on state spending for qualifying community-based mobile crisis intervention services, provider reimbursement rates, and eligibility for these services. These parameters will be important to Medicaid managed care entities, providers, and other stakeholders as they collaborate with states to design, develop, and implement this benefit.

HMA has worked with states to build out their crisis care continuum and stand up mobile crisis intervention models. Our work has included supporting states, counties, health systems, and providers to implement crisis services. In September 2021, CMS awarded $15 million in planning grants to 20 states to support expanding community-based mobile crisis intervention services for Medicaid beneficiaries. HMA is working in many of these states as well as in other states to facilitate assessment of community needs and develop programs to provide crisis intervention services to individuals who are experiencing a substance use-related or mental health crisis. Our experts are also supporting states and stakeholders to think globally about strategies and plans to integrate mobile crisis intervention services into their Medicaid programs and broader crisis and behavioral health systems of care.

HMA has also been helping states, counties, health systems, and providers implement the best and promising practices on both policy and programmatic levels. For example, states developing their Medicaid plan for community-based mobile crisis intervention services may consider incorporating the following best practices:

  • Develop a comprehensive crisis system, with mobile services as one key component
  • Identify, apply for, and implement Medicaid authorities that align these services within the broader system of care and current or new program structures
  • Update provider requirements, quality assurance activities, and service descriptions to align with state goals and CMS and Substance Abuse and Mental Health Services Administration (SAMHSA) guidance
  • Implement local/regional crisis call centers
  • Leverage technology to promote efficiency and close gaps in timeliness or workforce shortages, e.g. telehealth connections to providers and GPS technology to track teams in real time
  • Utilize paraprofessionals and peers across the crisis continuum and on mobile teams
  • Leverage diverse funding sources to promote sustainability
  • Address equity issues and traditionally marginalized communities 
  • Address crisis service workforce challenges
  • Partner across service systems and sectors (including court, education, 911 and law enforcement)
  • Ensure the community voice guides program design and oversight

Our diverse, interdisciplinary behavioral health team has extensive clinical, policy, operations and funding expertise in mental health and substance use disorder prevention and treatment.

HMA crisis intervention projects include: