The Need
Crisis situations can lead individuals who reside in the community to seek treatment or care in a hospital or institutional setting. Unfortunately, these emergency situations can often be the impetus for long-term placement in these settings. If preventive services were expanded, crisis response improved, and 13 | Colorado HCBS Spending Plan transitions strengthened, individuals may be able to, instead, return to their homes and communities.
Initiative 2.01. - Behavioral Health Transition Support Grants to Prevent Institutionalization
Under this project, the Department will offer short-term grant funding for behavioral health crises and transition services to support higher acuity members moving from an institution, hospital, or corrections to the community, specifically focusing on increasing capacity for community-based care. The Department would create grants for local communities, including providers, non-governmental organizations, and counties, to implement programs that are specific to their behavioral health capacity needs and geographic area. Grantees may request funding for implementation projects that improve service delivery options for crisis and transition programs or create pathways that improve care transitions. The focus will be on complex populations, with a history of institutionalization, and support step-down services specifically to help move individuals from inpatient to community settings. This grant would prioritize transition services that serve those that are disabled due to a mental health diagnosis.
Lessons learned from prior Department work transitioning members from long-term care institutions with the Colorado Choice Transitions Program will inform the design of the grant program, as will extensive stakeholder engagement. Providers may request funding for program improvements, infection control, staff training, best practice implementation costs, regulatory compliance, and community integration.
Initiative 2.02. - Expand Behavioral Health Mobile Crisis Teams
The Department will supercharge activities related to the mobile behavioral health crisis teams, which offer an alternative to police or Emergency Medical Services (EMS) transport for a person in a mental health or substance use disorder crisis. Currently in Colorado there are differing practices, pilots, and approaches to behavioral health crisis calls.
The Department will provide funding in the form of grants to support this effort. Grantees could utilize funding to start a program or to come into compliance by using funds for required staff training, increasing their capacity for 24/7 response, equipment purchases, and potential technology needs. Funds would also be available to create more culturally responsive mobile crisis services in Colorado.
Initiative 2.03. - Institute for Mental Disease (IMD) Exclusion, Risk Mitigation Policy
As a complement to the crisis service grant programs, the Department will explore the detailed policy and licensing requirements of different provision types that are federally prescribed when serving persons experiencing behavioral health crises. Colorado currently has a network of different facilities that can be used to assist a person in crises including Acute Treatment Units (ATU), Crisis Stabilization Units (CSU), emergency rooms, and when needed, traditional hospitalization. Both emergency rooms and hospitals come at higher costs, may lack behavioral health expertise, and may experience capacity issues to serve persons with medical needs when supporting persons in crises.
By contrast, ATUs and CSUs are especially adapted to behavioral health crises. However, to ensure the State’s new model of care from crisis response to crisis service delivery is successful, there needs to be compliance work completed with ATUs and CSUs. Crisis units must operate in compliance with federal Institutes for Mental Disease (IMD) regulations to receive Medicaid funding. Currently these crisis units are unable to serve and/or receive reimbursement for members who make up 70% of all calls to the statewide Crisis Services hotline.
To mitigate this risk, the Department will research and identify solutions for addressing IMD risk in these facilities. This would include a review of recent CMS guidance related to IMD to determine what actions can or should be taken to mitigate risk, including changing reimbursement policy, seeking a waiver, and/or working with other State entities to review licensing requirement reforms. The Department will also evaluate current ATU/CSU providers to review their programming and campus structure to ensure they do not meet the federal definition of IMD. The Department will generate recommendations on how to mitigate IMD risk as the state promotes the use of ATUs and CSUs in lieu of hospitalization or institutionalization, including the costs and benefits of the State seeking an 1115 waiver.