SENT ELECTRONICALLY
(https://townhall.virginia.gov)
June 21, 2023
Ms. Taneika Goldman
Director, Office of Human Rights
Department of Behavioral Health and Developmental Services
1220 Bank Street – 4th Floor
Richmond, VA 23219
RE: Public Comment on Draft Guidance for Peer-on-Peer Aggression
Dear Ms. Goldman,
On behalf of the Virginia Hospital & Healthcare Association (VHHA) and its hospital and health system members across the Commonwealth, please accept these comments submitted in response to the notice of public comment on draft guidance for Peer-on-Peer Aggression.
The safety of patients and staff is a high priority for hospitals, and we are committed to keeping everyone in our care safe. As consideration is made on the best way to maintain safety among patients’ considerable thought must go into ensuring that the proposed policy guidance will have its intended effect and not unnecessarily or unintentionally overburden providers.
As proposed, the guidance will be very difficult and burdensome to enter a CHRIS report and complete the required documentation for every verbal threat or demeaning expression from our patients. This type of activity occurs nearly every day at our member facilities. To avoid confrontation between patients, we remove patients from inappropriate situations and use de-escalation techniques to manage the milieu. However, providers are limited in their ability to control verbal comments made by or between patients.
To determine the appropriate level of supervision assigned to each patient, hospitals complete a thorough intake assessment, psychiatric evaluation, psychosocial assessment, and risk assessment. Whether staffing supervision requires 15-minute rounding or constant observation, we audit our performance and review incidents to ensure that the treatment plan and supervision were executed appropriately.
Hospital teams work very hard to prevent and manage patient behavior. The proposed reporting requirement will increase the administrative burden on providers when there are concerted efforts by the state to reduce such administrative burdens and as behavioral health providers remain severely understaffed.
VHHA and its members remain committed to ensuring the safety of all individuals seeking services in their facilities and understand the importance of providing the safest environment possible for patients and staff. At the same time, it is important that the proposed guidance meets the intended goal of reducing the incidence of peer-on-peer aggression but avoids imposing ineffective administrative burdens on providers.
Thank you for your consideration of these comments.
Sincerely,
Jennifer M. Wicker
Senior Director of Policy and Government Affairs