The Medicaid Mobile Crisis Option and What It Asks of Providers

In March 2021 the American Rescue Plan Act added a new section to the Medicaid statute: 42 U.S.C. 1396w-6, "State option to provide qualifying community-based mobile crisis intervention services." It gives states a time-limited option to cover mobile crisis services, with a higher federal match while the option lasts. For providers, the statute matters less for its financing than for its definition. It describes exactly what a qualifying mobile crisis team must be, and states that take the option build their provider standards from it.

What does the statute let states do?

A state may provide medical assistance for qualifying community-based mobile crisis intervention services "during the 5-year period beginning on the first day of the first fiscal year quarter that begins on or after the date that is 1 year after March 11, 2021" (1396w-6(a)). The statute sets aside several usual Medicaid rules for these services, including statewideness, comparability, freedom of choice of providers and the provider agreement rule, so a state can start in some regions or with designated teams.

For each of the first 12 fiscal quarters within that period in which the state meets the statute's conditions, the federal medical assistance percentage for these services is 85 percent (1396w-6(c)). To qualify, the state must show it can support services meeting the statutory definition and must use the extra federal money to supplement, not replace, its existing spending on these services; a state already offering them in a region must keep doing so (1396w-6(d)). Which quarters a given state has used depends on when it started and is a question for that state's Medicaid agency.

Which services qualify under the statute?

Under 1396w-6(b), the services must be furnished to a Medicaid-eligible individual who is outside a hospital or other facility setting and is experiencing a mental health or substance use disorder crisis. And they must be furnished by a multidisciplinary mobile crisis team that:

1. Includes at least one behavioral health care professional capable of conducting an assessment within that professional's scope of practice under state law, plus other professionals or paraprofessionals with crisis expertise, such as nurses, social workers and peer support specialists, as the state designates in its state plan or waiver.
2. Is trained in trauma-informed care, de-escalation strategies and harm reduction.
3. Can respond in a timely manner and, where appropriate, provide screening and assessment, stabilization and de-escalation, and coordination with and referrals to health, social and other services.
4. Maintains relationships with community partners, including medical and behavioral health providers, primary care providers, community health centers, crisis respite centers and managed care organizations where applicable.
5. Protects privacy, maintaining the confidentiality of patient information consistent with federal and state requirements.

The services must be available 24 hours a day, every day of the year (1396w-6(b)(3)).

For a provider, what does that mean on paper?

Each element of the definition becomes something a state can check, and something your program needs to document:

• A staffing roster and coverage schedule that shows a qualified assessor on every shift, every day of the year, with licenses verified and current. The professional's scope comes from state law, so the clinician's license type matters; our sister sites license counselors and social workers.
• Training records for trauma-informed care, de-escalation and harm reduction, for every team member.
• Written response procedures, from dispatch through screening, stabilization and follow-up, with the response-time standard your state sets.
• Partnership agreements with the providers, health centers, crisis respite programs and managed care plans the team hands people to.
• Confidentiality policies that fit your program. A crisis team run by a federally assisted substance use disorder program is subject to 42 CFR Part 2 as well as HIPAA; see the 2024 Part 2 rule.
• Medicaid enrollment as the provider type your state designates for mobile crisis.

Do states license mobile crisis teams?

Some do, and the rules differ. Arizona, for example, licenses behavioral health observation and stabilization services as part of a behavioral health facility license and adds a fee of $94 times licensed occupancy (A.A.C. R9-10-106(C)(3)). Before launching, confirm whether your state requires a separate crisis license or certification, a change to your existing license, or only Medicaid designation. Our state licensing index shows what we have verified.

How do CCBHC crisis standards compare?

They are stricter on timing. SAMHSA's 2023 CCBHC criteria expect mobile crisis teams to arrive in person within one hour, or two hours in rural and frontier settings, never exceeding three hours, and SAMHSA's FAQ says a telehealth-only response does not meet that standard. A CCBHC may use a state-sanctioned crisis system as a Designated Collaborating Organization for its crisis services. A program that wants to serve both roles should build to the stricter standard. See CCBHC certification: the nine services and the 2023 criteria.

Where do we fit?

We license and document programs; we do not run crisis lines, dispatch teams or handle people in crisis. For a provider standing up a mobile crisis program, that means the state license or certification (our outpatient license package is $1,995 for one site, and each additional site or service component is $595), a Policy and Procedure Manual ($1,495) written to your state's crisis rule and the statutory elements above, and Medicaid Facility Enrollment at $499 per state. Your officers sign every application and you pay state fees directly. Not sure what your state requires? The $149 Facility Readiness Review maps it first.