On January 10, 2022, California Governor Gavin Newsom released his 2022-2023 Budget Proposal that includes a total spending of $286.4 billion in State Funds ($213.1 billion from the General Fund) and another year of historic $217.5 billion investment in health care. The budget proposal builds on existing Medi-Cal expansions and includes $108 million total funds ($16 million General Fund) to add community-based mobile crisis intervention services as a new Medi-Cal benefit. As the COVID-19 public health emergency continues to impact California’s healthcare system and residents in many ways, this Medi-Cal benefit is crucial to building and sustaining an effective behavioral health crisis continuum of care.
WHAT is the federal authority for adding this Medi-Cal benefit?
The American Rescue Plan Act of 2021 (ARPA), one of the federal COVID relief packages enacted by Congress, amends Title XIX of the Social Security Act (SSA) to add the new Section 1947 that authorizes 85% federal matching funds for 12 quarters during a 5-year period for states to implement a “qualifying community-based mobile crisis intervention services” option in their Medicaid programs starting April 1, 2022.
WHAT are “qualifying community-based mobile crisis intervention services”?
Community-based mobile crisis intervention services are crisis intervention services provided to individuals experiencing a behavioral health crisis whenever and wherever the service is needed. In California, “Crisis Intervention” is defined as “a service, lasting less than 24 hours, to or on behalf of a beneficiary for a condition that requires more timely response than a regularly scheduled visit.”
To meet the “qualifying” requirement, community-based mobile crisis intervention services must be:
- Provided to a Medicaid beneficiary who is experiencing a mental health or substance use disorder crisis;
- Provided outside of a hospital or other facility setting;
- Furnished by a multidisciplinary mobile crisis team that consists of at least 1 behavioral health care professional capable of conducting an assessment of the individual AND other professionals or paraprofessionals with appropriate expertise in behavioral health or mental health crisis response (e.g. nurses, social workers, peer support specialists, etc); and
- Available 24 hours per day, every day of the year.
Additionally, the mobile crisis team members must:
- Be trained in trauma-informed care, de-escalation strategies, and harm reduction;
- Be capable of responding in-person to the crisis in a timely manner;
- Be able to provide services, such as screening and assessment, stabilization and de-escalation, as well as follow-up care coordination, referrals, and transportation assistance as needed; and
- Maintain the privacy and confidentiality of patient information and relationships with relevant community partners.
Information on the scope of and payments for qualifying community-based mobile crisis intervention services can be found in Medicaid guidance issued by the federal Centers for Medicaid and Medicaid Services (CMS).
WHAT does California’s current crisis intervention service look like?
Since 2013, the state has been providing crisis intervention, crisis stabilization, and crisis residential treatment services to Medi-Cal beneficiaries through Mental Health Plans (MHPs) under its Speciality Mental Health Services Program. Currently, crisis intervention services may be provided “anywhere in the community,” but it is not required to be mobile and may be provided face-to-face or by telephone. Also, unlike crisis stabilization that must be provided on-site at a 24-hour licensed or state certified facility and by providers who meet specific staffing requirements, crisis intervention is not required to be offered 24/7 and may be provided by “any person determined by the MHP to be qualified to provide the service….”
Under the federal Medicaid’s Early and Periodic Screening Diagnostic and Treatment (EPSDT) mandate, crisis intervention services, including mobile crisis intervention, must be provided to children and youth on Medicaid under age 21, when such services are medically necessary to correct or ameliorate a behavioral health condition (see NHeLP’s recently published issue brief Children’s Behavioral Health Mobile Response and Stabilization Services for more information on this obligation). Yet, despite being a covered benefit in California’s Medi-Cal program, these services are not sufficiently available throughout the state and in fact not provided at all in 14 counties.
WHAT does this Medi-Cal benefit mean for California’s behavioral health system?
Starting as soon as January 1, 2023, California will take up the option in its Medicaid state plan to provide mobile crisis intervention service for beneficiaries with behavioral health conditions as a mandatory Medi-Cal benefit.
To continue receiving the enhanced federal matching fund, California will have to ensure that its crisis intervention service meets all of the qualifying requirements mentioned above (such as 24/7, multi-disciplinary, and mobile). The Department of Health Care Services (DHCS) plans to implement this benefit through county behavioral health delivery systems by community-based multidisciplinary mobile crisis teams. In 2022, the state will also develop a plan to support connections between the various prevention and intervention systems, including hotlines, 9-8-8 crisis call centers, peer support services, and mobile crisis service response. A coordinated plan is essential to ensure these benefits are available statewide, in a timely manner, to all Medi-Cal beneficiaries who need them.
