Comments in Response to Virginia Crisis Continuum Best Practices Draft Document
Thank you for the opportunity to provide comments. Please see below.
| Guidance Category | Draft Language | Comments |
| Overview |
page 5 "The purpose of this document is to provide the DBHDS' explanation of best practices for the crisis continuum." |
It is not clear how this document will be used--is it a planning document for agencies considering initiating these services? Is there an expectation that these become required elements? |
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page 5 Comprehensive Crisis Continuum |
Hospitals are not included and while we all strive to avoid hospitalization, they are an important part of the continuum of services provided. | |
| Service: Regional Crisis Contact Centers |
page 7 "A regional crisis contact center (RCCC) offers real-time access to trained crisis workers 24 hours per day, seven days per week." |
Many CSBs also staff locality-based Crisis Contact Centers that serve a similar function to the regional CCCs. Are there the same or different expectations for the locality-based centers? |
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page 7 "Be staffed with clinicians overseeing clinical triage and other trained team members to respond to all calls received." |
Do most of the RCCCs use "clinicians"? | |
| Service: Mobile Crisis Response | pages 10-12 | Is MCR considered the same as Marcus Alert Co-Response teams for the purposes of this document? In our locality, they are not equivalent. |
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page 12 "All provider employees are required to complete..." |
This should be all employees providing the service. | |
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Service: Community Stabilization- Non-Residential |
page 13 "Providers must have an active, DBHDS approved, MOU or contractual agreement with the regional crisis hubs prior to providing mobile crisis response services." |
Is this language in Section G of the DMAS Manual? Is this sentence referencing this section of the regs: "The provider must engage with the DBHDS crisis data platform as required by DBHDS." |
| Service: Crisis Receiving Center |
page 15 "CRCs should assess and triage individuals experiencing a behavioral health in any level of acuity crisis 24 hours a day." |
There seems to be a word missing within this sentence. |
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page 16 "Guests of the CRC shall receive a clinical assessment by a Licensed Mental Health Professional (LMHP)." |
Would like the consideration of adding "...shall receive a clinical assessment by a LMHP or license-eligible LMHP." | |
| Service: CITAC |
page 18 "CITACs are operated by CSBs or BHAs, who must meet the qualifications, credentialing standards, and training components that are outlined in the performance contract." |
Our CITAC is operated through a local hospital system. |
| Service: Crisis Stabilization Unit |
page 19 "If a CSU provides serves an individual under a Temporary Detention Order (TDO)..." |
This should be "if a CSU provider..." |
| Services: CSB Emergency Services |
page 20 "Emergency services employees complete preadmission screening and civil commitment hearing activities as required by Chapter 8 of Title 37.2 of the Code of Virginia. Other services provided may vary by Community Services Board (CSB)." |
This section provides a very narrow description of Emergency Services tasks. Our ES provides services beyond these, including staffing a 24/7 call line, providing consultation to internal and external agencies such as local police, and coordination with other agency programs to manage crisis situations. Additionally, ES takes an active role in identifying the least restrictive treatment options to mitigate a crisis, oversees safety planning, and follows up with linkages to community resources. Emergency Services works around the clock to problem solve and, when possible, avoid people having to be prescreened and go through the civil commitment process. When unavoidable, ES also has the role in locating a bed for inpatient treatment. Is the goal of this document to limit the role of ES to just prescreenings and hearings? |