Overall, the proposed licensing changes create significantly more far –reaching regulations, especially in areas of administration and governance, all of which amount to unfunded mandates for providers. In the absence of additional resources to meet the proposed requirements, providers’ existing resources will necessarily be directed away from actual treatment and service to clients and instead be allocated towards meeting these unnecessarily burdensome administrative requirements. 

Emergency services (crisis intervention)- Emergency services shall provide immediate mental health care in the home or community to assist individuals who are experiencing acute psychiatric dysfunction requiring immediate clinical attention

Feedback:  This suggests a mobile crisis response capability which is not funded and not available in all CSBs’ Emergency Services.  The STEP-VA Mobile Crisis initiative and associated funding will support expansion of mobile crisis capability, but this will be regionally managed and a separate service than Emergency Services.  “Mobile Crisis” should be separately defined and this sentence removed from the ES definition.