New River Valley supports comments made by Beth Ludeman-Hopkins, Horizon Behavioral Health and Kathy Nelson, HRCSB. Specific comments are addressed below:

12VAC30-50-226A Amend language to be clear that the term "certified pre-screener" continues to apply exclusively to CSB/BHA clinicians in their role of providing emergency services and pre-admission screening for involuntary detension. Identify clinicians as "certified CSB/BHA pre-screeners."

12VAC30-50-226A Develop an equivalency consideration for full-time experience and a flexiblity consideration for alternative degrees to avoid severely limiting the pool of potential providers.

12VAC30-50-226A-QMHP-A and C - Grandfathering and variances will be essential to retaining staff to provide these services.

12VAC30-50-226B Continue licensure through DBHDS for ICT based on the PACT model. Consider language more appropriate to the client level of need such as "when services that are far more intensive than outpatient clinic care are required and services in the home and the community are more likely to be successful."

12VAC-50-130 Activities of Daily Living - Consider expanding elements of daily living to other basic need requirements for people with serious mental illness including shopping, budgeting, meal planning and preparation, and medication management.

12VAC30-60-61A The stringent definition of "at risk" may result in few children and adolescents with SED qualifying for Intensive In-Home. The absence of Intensive In-home services with this population weakens the outcomes of other services by creating significant service gaps. Outpatient and school-based services are not adequate to meet the needs of many of these clients.