14 comments
As a Licensed Clinician and Clinical Supervisor in the state of Virginia, I am extremely concerned about the new crisis protocols. Private providers are tasked with providing 23hr crisis services to individuals in the community who are often dual diagnosed with mental health and substance abuse needs and there is minimal safety protocol. I am hearing that these facilities have one LPN (under supervision of RN, unsure of when they supervise how is this tracked) that check vitals on intake prior to a clinical assessment. According to residents that I train and supervise there is no required UDS, a psychiatrist or NP is not available at most facilities. I asked about training for Narcan for the possibility of heroin overdose, there is not policy about weapons or drugs in the facility. There isn't even a policy on drug interaction or food allergies protocols. This service is intended to be an intervention prior to the hospital but is not required to do any of the required medical and or safety protocols hospitals have to report as part of their intake assessment.
There are obvious safety concerns not to mention the ethical concerns of assessment individual prior to determining if there is a significant level of intoxication.
I know that this is a critical resource, and I am concerned about the actual benefit to the patients. When a company can essential add on a higher level of care for individual who are already at a higher level of acuity and are able to bill and be reimbursed for 1 hr. or 23 hours, it opens up several issues. Individuals are quickly assessment and funneled to community crisis in the same business. We know many of this companies are using hotels to manage housing needs in community programs and housing is a huge impacting issue.
I would suggest a minimum observational time and initial urine screens in 23 hr crisis. The individuals that access crisis services need staff and clinicians trained in safety protocol, medication management, and clinical training for both mental health and substance use disorder.
There needs to be a restructuring of these programs to better serve the people who need them most.
I am writing to provide feedback on the proposed regulations for Crisis Services, specifically addressing several points outlined in the sections of 12VAC35-111. I appreciate the opportunity to contribute to this important discussion and recommend adjustments to ensure these regulations are effective and aligned with best practices.
12VAC35-111-10 - Definitions:
I recommend using “Community Stabilization” instead of “Community Based Crisis Stabilization” to maintain consistency with DMAS language and service definitions.
Adjusting the language from “…experiencing a behavioral loss of control” to “behavioral crisis” aligns closer with a person-centered approach.
12VAC35-111-20- Licenses:
I recommend the following licenses: Crisis Receiving Center, Community-based Stabilization, Mobile Crisis Response (includes REACH MCR which should be licensed under this), Emergency Services, REACH Community Stabilization, REACH Crisis Therapeutic Home, and Crisis Stabilization Unit.
12VAC35 – 111-30 Service Descriptions:
Clarification is needed regarding the requirement of a nursing assessment, as it contradicts the regulation stating that nursing assessments are not required for Crisis Receiving Centers.
The regulation should state that providers shall have a policy to address custody of children accompanying parents but shall not be responsible for the children’s safety on the unit.
12VAC35 – 111 – 40 Staffing:
The requirement in Line B2 may be specific to the VCC platform and is not appropriate for inclusion in licensing regulations.
Providers of mobile crisis response do not “dispatch” calls; the regulation should be revised to read: “If a team response is recommended at dispatch…”
Change the language from QMHP-E to QMHP-T in Line B3 ii - 6.
12VAC35 – 111 – 50 Initial Contacts:
Define “initial contact” in the definitions section for clarity.
Recommend adding clarifying language regarding intent or removing added reporting requirements.
Service linkages or referrals should not be required unless a service is rendered.
12VAC35 – 111 – 80 Safety plan and Crisis ISP requirements:
Omit the underlined portions to reduce administrative burden.
The focus should be on clinical treatment rather than documenting attempts to obtain signatures.
12VAC35 – 111 – 90 Reassessments and Review of Safety Plans and Crisis ISPs:
Clarify which services this regulation applies to; it should not apply to services that are for 72 hours or less.
12VAC35 – 111 – 110 Discharge Planning:
Correct the code reference to 12VAC35-105-693.
The Discharge Planning section needs clarity and consistency regarding required services and steps.
12VAC35 – 111 -120 Written policies and procedures for crisis or emergency response; required elements:
Remove “face sheet” terminology for clarity.
12VAC35 – 111 - 130 Nursing assessment:
Ensure alignment with DMAS regulations and clarify the type of service setting this requirement pertains to.
Nurses should not be responsible for diagnosing underlying conditions.
12VAC35 – 111 – 140 Health Care Policy:
Revise to focus on addressing “acute” medical and dental needs only.
These recommendations aim to improve the clarity, consistency, and effectiveness of the proposed regulations for Crisis Services. These adjustments will better support providers in delivering person-centered, trauma-informed care while reducing administrative burdens.
I look forward to the continued progress and improvement of Crisis Services in our community.
Please consider requiring a prescriber role for all 23 hour programs; some of the models being rolled out in Virginia are more similar to a Behavioral Health Urgent Care which does not fill the gaps that exist in our current crisis setting.
OVERALL COMMENT:
Overall, it is believed that lumping Crisis Stabilization, Mobile Crisis Response, REACH, and Emergency Services into a single license there is a general lack of clarity and the context in which each service is provided is lost. Each service has a defined purpose across the crisis continuum and in some cases such as pre-admission screening, it creates blurred boundaries of public and private responsibilities outlined in Virginia Code and does not properly take into account the unique training required by Pre-Admission Screeners. We recommend separate and distinct licenses for each of these services to clarify staff training requirements, team compositions, and to maintain fidelity to the services outlined.
Please see the recommendations/clarifications below per section of the draft.
12VAC35-111-10 - Definitions
Behavior Interventions: This definition does not provide clarity to know when this would apply. Due to the nature of an MCR and / or Emergency Services Pre-Screening, it cannot be presumed that assessors will consistently have access to assessment / records for services rendered outside of their own agency.
Community Based Crisis Stabilization: It is recommended that “Community Stabilization” should be used instead of “Community Based Crisis Stabilization” to be more consistent with DMAS language and service definitions. The following definition revision is recommended:
“Community-based crisis stabilization” means services that are short-term and designed to support an individual and their natural support system following contact with an initial crisis response service or as a diversion from a higher level of care. Providers deliver community-based crisis stabilization services in an individual’s natural environment whenever feasible; services provided in a setting that is not the person’s natural environment should be clinically justifiable and with reasons for such documented in the ISP and progress notes. Providers will make referrals and linkages to other community-based services with consent by the individual, which may include linking to specialized services such as those to address needs of individuals with developmental disabilities, children, and / or individuals needing support with substances. Provision of information and / or linkages to resource assistance programs and / or benefits a person may be eligible to receive may be provided if through this linkage a person’s socioeconomic stressors are likely to be reduced and potentially reduce likelihood of future crises. The goal of community based crisis stabilization services is to stabilize the individual within their community and support the individual and/or, as appropriate, the individual’s support system during the periods 1) between an initial mobile crisis response and entry into an established follow-up service at the appropriate level of care 2) as a transitional step-down from a higher level of care if the next level of care service is identified but not immediately available for access or 3) as a diversion from a higher level of care.”
Crisis Education and Prevention Plan (CEPP): It is recommended to adjust the language from “…experiencing a behavioral loss on control” to “behavioral crisis” as this language aligns closer with a person-centered approach.
Initial Assessment: It is unclear what is being clarified with the added language “an assessment is not a service”.
Initial Individualized Service Plan: The timeframe states 24 hours but we need to double-check that this is consistent in all specific services as we were thinking that CSU gives 48 hours to complete the crisis ISP. (see pg. 16)
Is this referring to the “Crisis ISP” that is referenced throughout the rest of the document? Recommend removing “Initial ISP” def and replacing with a clear definition for Crisis ISP.
12VAC35-111-20- Licenses
Pg.9:
The following licenses are recommended:
12VAC35 – 111-30 Service Descriptions
A – Crisis Receiving Centers: It is indicated that a nursing assessment is required. This contradicts the regulation in the Nursing Assessment section that indicates that nursing assessments are not required for Crisis Receiving Centers.
The regulation states that CRCs shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that the provider shall have a policy to address custody of children accompany parents but shall not be responsible for the children’s safety on the unit. Additionally, there should be a requirement for addressing children being assessed at the Crisis Receiving Center accompanied by their parents.
B – Community Based Crisis Stabilization: Combining multiple services under one license presents as very confusing in terms of what services are required to providers. Recommend breaking out service by service in the regulations as outlined above in the list of recommended licensed services.
It is suggested that “Emergency Services” and requirements of uniform pre-admission screening be clearly defined under a unique license to reflect the codified responsibilities and training / supervision requirements that are significantly unique to this public / mandated service.
C – Crisis Stabilization Units (RCSU): The regulation states that providers shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that the provider shall have a policy to address custody of children accompany parents but shall not be responsible for the children’s safety on the unit. Additionally, there should be a requirement for addressing children being assessed in a CSU to be accompanied by their parents or other legally designated substitute decision-maker (ie., DSS, kinship placement, etc).
D : The proposed regulation indicates that individuals cannot enter into “a REACH service” if they are actively using substances; however this is too broad as substances include nicotine, THC / CBD, etc. which do not / should not preclude someone from accessing REACH services. We DO strongly support the section related to not being able to support someone [at a REACH CTH] who is in active detox.
12VAC35 – 111- 40 Staffing
B: Community Based Crisis Stabilization Staffing for the community based crisis continuum services is complex and even more so in this section due to the bundling of multiple services under a singular license. It is recommended that these services are broken out under separate licenses to ensure accurate staffing requirements are addressed.
B1: Recommend to update to specify that the assessment is a crisis assessment and remove the CEPP language.
B2: This requirement is possibly a requirement of the VCC platform and is inappropriate to include in a licensing regulation.
B3 ii: Providers of mobile crisis response do not “dispatch” calls as this is a function of the regional hub and PRS/988. It is recommended to rephrase the regulation to read: “If a team response is recommended at dispatch…”
B3 ii – 6: It is recommended to change the language from QMHP-E to QMHP-T
C5 - A separate license is recommended for the REACH CTH; the MCO’s accept this definition for billing purposes. We would benefit from having licensing also recognize the REACH CTHs as a setting that provides crisis stabilization services. Recommend ensuring alignment with DOJ requirements.
D - It is recommended to not treat REACH differently than the rest of the crisis continuum when it comes to licensing regulations. The REACH Standards also, are not licensing regulations and therefore licensing regulations should not point readers / programs to this document which is not kept current and does not presently align with these draft regulations. Having separate guidance documents is not beneficial to community or providers. Additionally, REACH provides Community Crisis Stabilization, MCR and Crisis Therapeutic Home services, however Crisis Therapeutic Home regulations do not presently exist. It is further confusing for regulations to reference that some of the CTHs operate under RCSU licensing regulations; The REACH CTHs require their own CLEAR set of expectations to ensure consistency in operations, reduction in barriers to admission and consistency in systemic oversight statewide.
12VAC35 – 111 – 50 Initial Contacts
A -It is recommended that “initial contact” be defined in the definitions section.
This requirement is overly cumbersome administratively for inquiries that are not of a crisis nature. Please add clarifying language regarding intent OR recommend that these added reporting requirements be removed. Additionally, making service linkages or referrals would not be in scope depending on the type of services that is being contacted, unless a service is rendered.
12VAC35 – 111 – 60 Assessment
D: A crisis assessment is not the same thing as a comprehensive assessment due to the nature of the service and availability of records in a crisis.
It is recommended that the current DBHDS approved crisis assessment components align with the regulations as they currently do not match what is written here. The elements listed in the draft regulations are more closely aligned with a CNA than the crisis assessment.
F(10)b: For Crisis Stabilization Units and Community Based Crisis Stabilization, it is recommended that the regulations allow for providers to complete an addendum to the assessment; if a general crisis assessment or pre-screening is completed within the last 72 hours, an addendum should be allowed. Engaging an individual in an assessment process multiple times does not align with a person-centered or trauma-informed approach to care, particularly when a person is presenting as unstable due to crisis needs.
H: Record retention should not be included as it is already covered in the general regulations.
12VAC35 – 111 – 70 Safety plans and Crisis ISP
B: It is recommended that a singular CEPP be required for REACH services; A Safety Plan at the point of crisis assessment with a CEPP developed during the course of community crisis stabilization admissions or CTH admission would align more closely with the rest of the Crisis Continuum.
12VAC35 – 111 – 80 Safety plan and Crisis ISP requirements
D1 & D2: It is recommended to omit the underlined portions. Undue burden is placed on providers of short term, crisis services to make multiple attempts to obtain signatures beyond 48 hours. There is too much focus on documenting the attempts to obtain client signatures than on the clinical treatment they are in need of and receiving. Attempts are made to obtain signatures within the first 48 hours; documenting refusals and attempts during that timeframe should be sufficient as ongoing attempts beyond that period can damage the therapeutic relationship / trust and places focus on the wrong aspect of care.
12VAC35 – 111 – 90 Reassessments and Review of safety plans and Crisis ISPs
A: This section should clearly define what services this regulation applies to. It is recommended that this regulation does not apply to services that are for 72 hours or less.
12VAC35 – 111 – 100 Progress notes or other documentation
A: It is recommended that these regulations be further clarified or completely omitted from draft as it is redundant to section B which includes specifics of what should be included in progress notes.
B: Recommend removal of this item; general regs should suffice for progress note documentation
12VAC35 – 111 – 110 Discharge Planning
A: It appears the wrong code is referenced; the correct code should be 12VAC35-105-693. In general, the entire Discharge Planning section is unclear and contradictory in terms of what services are required to do and at what discharge planning steps.
B: It is unclear why a Crisis Receiving Center would not be required to provide discharge planning instructions and coordinate care with the rest of the service system on behalf of the individual served.
G: It is recommended that we document progress towards Crisis ISP instead of language related to “criteria for discharge” which adds additional burden for crisis services that supersedes what longer term services are providing.
12VAC35 – 111 -120 Written policies and procedures for crisis or emergency response; required elements
C4: It is recommended to remove “face sheet” terminology as the emergency medical information is present in different locations depending on the agency EHR.
12VAC35 – 111 - 130 Nursing assessment
A: This regulation does not align with DMAS regulations which require the nursing assessment at admission for any residential service and the 23-hour program. It was also noted previously that this regulation contradicts the regulation in 12VAC35-111-30. Service Descriptions (A).
C: The first sentence should be revised to “Prior to admission to (specify which service type)…”
D: Recommend removal of the first sentence as it is not needed or clarify as a “medical professional” shall conduct a nursing assessment.
It is recommended to clarify the type of service setting this requirement pertains to as resources vary by organization. It is also recommended to remove all language between “transfer to a more intensive level of care” and the last sentence of the paragraph. Nurses are not responsible for diagnosing underlying conditions.
H: It is recommended to add the qualifier “unless the provider has access to a shared electronic health record.”
12VAC35 – 111 – 140 Health Care Policy
B4: It’s unreasonable to expect CSUs and CTHs providing short term services to schedule “routine ongoing and follow up” medical and dental appointments; recommend revising to reflect need for this support to address “acute” medical and dental needs only.
C: General regs should cover the fall risk requirements; also, all services that admit a person to treatment are required to do a fall risk assessment so this is not inclusive of other services that are required to complete the fall risk assessment.
12 VAC35-111-230 Nutrition
B.1.b: Recommend remove the “provide methods to learn” from this requirement as this is unclear what all is being asked of the programs. Typically dietary needs of patients is specified on medical orders.
B.2.e: What is “periodically?” If this is not anticipated to be monitored / regulated, recommend removing.
12 VAC35-111-240 Beds or Recliners
G: Recommend removal of this item; tracking the number of days between laundering sheets is administratively burdensome. Physical environment / site visits should focus on whether the bedding is “clean” as specified in item A of this section.
12 VAC35-111-250 Bedrooms
B 1 & 2: Recommend language that indicates that for New services to be licensed they must meet these specified dimensions so that existing services that may not meet these specifications can be grandfathered in.
D: Same comment as B1&2 re: existing sites and grandfathering
E: Recommend “reduce risk” instead of “prevent” language since it’s impossible to fully prevent risk of harm to self by others
I: Clarify “provide separate sleeping areas” - does this mean separate wings or separate bedrooms.
J: This appears to be pulled directly from Children’s PRTF / Residential Treatment regs; question whether this is a needed requirement
12 VAC35-111-260 Physical environment
F: These water temps do not align with general physical env regs; recommend NOT attempting to duplicate sections of the general regs in each separate service regulations due to risk of inconsistencies and increased admin burden on not only licensing but the provider system.
M: Remove “prevent harm” language and replace with reduce risk language
O: This section was pulled from Children’s PRTF regs which is NOT the same level of care as Child CSU / CTH.
O.2 –Example It’s HIGHLY unusual for a CSU to have a Bathtub in their facilities
P1: Video cameras exist outside entrance in many cases; recommend revising language to be that the provider obtain written consent at admission instead of “Before admission”
12 VAC35-111-300 Floor plan and building modifications
What constitutes a building renovation especially for buildings where you incur a lot of damage. It’s a burden that every time you paint a wall, etc. that you need to submit this, especially when you require the building to be in good condition
12 VAC35-111-310 Lighting
Not consistent with other sections or chapters; please clarify if other sources are allowed when the electricity is out.
thank you for the opportunity to provide comments, offer suggestions, and ask questions.
Definitions:
P. 3 Behavior interventions – this is unclear when it applies. Concerns raised that ES and MCRs will not be developing ISPs and will not have these docs to reference in the acute response, typically
Community Based Crisis Stabilization--recommend using “community stabilization” to be more consistent with DMAS language and service definitions; non-center based location in an individual’s natural environment[ as possible]
Contracted Employee / Contractor – Recommend strike Employee and just use Contractor only.
CEPP – rephrase to “behavioral crisis” which is more person centered than behavioral loss of control
p.5 - Initial Assessment – This is stating that an assessment is not a service, but it is, we have to do that in order to provide any on-going interventions, and we bill for it to DMAS. So perhaps this could be more consistent with DMAS language since the process should be consistent whether DBHDS is describing it or DMAS is.
Initial ISP - Also, the timeframe states 24 hours but we need to double-check that this is consistent in all specific services as we were thinking that CSU gives 48 hours to complete the crisis ISP. (see pg. 16)
Please define Crisis ISP in the definitions list; is the Crisis ISP intended to be Initial ISP?
There is CEPP and Safety Plan language throughout and we assume that the intention is not to require both.
Pg. 9 Paragraph 1: Recommend the following licenses:
• Crisis Receiving Center
• Community-based Stabilization
• Mobile Crisis Response
• Emergency Services
• REACH Mobile Response and Stabilization
• REACH Crisis Therapeutic Home
• Crisis Stabilization Unit
Pg. 9 Paragraph 2: Line 7, a nursing assessment is required, however; on page 19 under “Nursing Assessment” the regulation states that nursing assessments are not required for Crisis Receiving Centers.
Pg. 9 Paragraph 2: Lines 11-12, a CRC shall have policy to address custody of children accompanying a parent for treatments, but shall not be responsible for maintaining those children’s safety on the unit. Additionally, there should be a requirement for addressing children being assessed at the CRC and accompanied by their parents.
Pg 9 Paragraph 3: See comments related to confusion of lumping multiple services under one license above.
Pg. 9 Paragraph 3: Pre-admission screening and Emergency Services should be properly defined under a unique license to reflect the codified responsibilities and training unique to this service.
Pg. 10 Paragraph 1: Lines 9-10, See Comment 6 above.
Pg. 10 Paragraph 2: Lines 7-8, Individuals utilizing substances are not prohibited from enrollment in REACH services.
P. 10 Staffing:
B. Community Based Crisis Stab – we recommend add “crisis” assessment and strike CEPP language
B6. Recommend changing from QMHP-E to QMHP-T for consistency
C5 – No need for this added language
P.11 – Initial Contact- We ask for clarification because this doesn’t seem to be broad enough to capture what happens in crisis services. the Crisis Center would not capture all of the information mentioned in this section with someone who walks in just to get resources. Also, making service linkages / referrals would not necessarily be in scope (from an inquiry only) depending on the service type that is being contacted unless a service is rendered to the individual.
P. 12 D – Assessment – Crisis Assessment is not able to be comprehensive due to the nature of the service and available records in a crisis.
P. 13 b- for crisis stab units and comm based crisis stab; recommend that we allow for an addendum to a recent assessment to meet the requirements; If pre-screening is completed within the last 72 hours, allow for an addendum (recommend aligning more closely with DMAS). It’s not person-centered / trauma-informed to re-assess numerous times
P. 13 H- record retention – should this be included in licensing regs? There are LOV regs that we follow already.
P. 16 D1 & 2- Recommend not to include the underlined portions. Undue burden on providers to continue attempting to obtain beyond 48 hours ; puts focus on the client signing documents than on clinical treatment. We attempt to obtain signature for first 48 hours but documenting refusals to sign and / or receive should be sufficient; ongoing attempts can damage therapeutic relationship / trust and places focus on the wrong aspect of care.
P. 17 – Recommend that Emergency Services’ Pre-Screening process be pulled out as a completely separate and discrete service
P. 17 – Reassessments and Review of Safety Plans and Crisis ISPs- Clearly define what services this applies to; recommend that this not apply to a 72 hour or less
p. 17 – Progress Notes or Documentation:
A. Recommend further clarifying this or striking all together; redundant to item B which includes specifics of what should be included in progress notes;
B. Recommend removing item 3; every note may not
p. 18. Discharge Planning
A. In general, this entire section is unclear and contradictory in terms of what services are required to do what discharge planning steps.
G- Recommend that we document progress towards Crisis ISP and versus language related to “criteria for discharge” which adds additional burden for crisis services that exceeds what even longer term services are providing.
P. 19 – Written Policies
C4 – Remove “face sheet” terminology as the emergency medical information is present in different locations depending on the agency EHR
P. 19-20 Nursing Assessment
A – Doesn’t align with DMAS regs which requires the nursing assessment at admission for any residential service and the 23 hour programs.
C- Specify prior to admission to [specify which service types]
D- “A staff member” should be replaced by a qualified medical professional or remove this sentence
D- Clarify type of service as resources vary by service type. We would also recommend removing everything between “transfer to a more intensive level of care” and the last sentence where the examination is documented and signed or significant clarification of the intent of this section; nurses are not responsible for diagnosing underlying conditions.
H- add qualifier “unless the provider has access to a shared electronic health record.”
Health care policy:
B2: Crisis ISPs will address ANY medical/dental – that is broad to address ANY medical care needs in a short term service. Is this meant to be about related medical or dental serious issues that impact the crisis?
B3: Seems too broad – do they mean for immediate needs? Change routine to emergent/urgent. Leave 3/take out 4
C – is this in general chapter for licensed services?
Vital Signs:
Interesting that it specifies taking vitals at time of discharge.
CRC’s are not there for lengthy period, so how often are we going to be checking BP
We’re having to develop procedure, but we’re going to go by a doctor’s order, which could vary by patient
Emergency preparedness and response plan:
This is in general chapter as well, why is it being added to specific chapters. By embedding in separate chapters, it’s more maintenance for licensing to touch every reg for review when something changes and causes administrative burden and we would recommend not adding. And there is nothing here that is specific to crisis services.
Nutrition:
1 – not consistent with existing regulations
1 a - We don’t get dietary orders for a “normal diet”
1 b and 2 - This is complex for a short term service and is going above and beyond for a crisis service. Providing methods to learn seems to infer that we need to give cooking classes. We don’t document what individuals eat daily and how are you going to document the outcome of menus?
Beds/recliners:
B. this is helpful (having ability to have cots)
C: individuals often prefer to do their own laundry and should be able to.
G: suggestions: Let individuals know that if they want linens changed during their stay to let us know, but requiring them to be changed at 7 days is cumbersome for the constantly changing roster. Admissions are revolving and this would be an administrative burden to track. E. covers G.
Physical space:
D: Is there a grandfather clause for existing spaces that do no meet these regs?
E: suggest "reduce risk from harming self" instead of "prevent."
I and J: Is this referencing children’s residential services such as PRTF and TGH? If this CRCSU and CTH, does this mean separate wings or rooms?. This seems to be referencing children’s residential services and CRCSU’s are licensed as CSU’s, not under children’s residential services.
Physical environment:
F: Water temperature does not match current general chapter and how there are inconsistencies when chapters are copied over. Temperature is currently capped at 110.
M 2 – not all facilities are “ligature free” because they strive to be home like. Suggest replace the word prevent with "reduce risk."
O. Providers of children’s residential services – strike out all info below as CRCSU’s are not licensed as children’s residential services, they are licensed as CSU’s.
P1: upon admission instead of before the individual is record – because there are cameras on the outside of the buildings, wording should be changed to add the time of admission
Fire inspections – repealed code section
Lighting:
Not consistent with other sections or chapters
Goes into more details than in other places
Clarify if you’re going to say that artificial lighting should be by electricity – will we get cited for solar power, candles, lamps?
Thank you for the opportunity to make comment on these proposed regulations. My comment/questions are below:
Overall, it is believed that lumping Crisis Stabilization, Mobile Crisis Response, REACH, and Emergency Services into a single license there is a general lack of clarity and the context in which each service is provided is lost. Each service has a defined purpose across the crisis continuum and in some cases such as pre-admission screening, it creates blurred boundaries of public and private responsibilities outlined in Virginia Code and does not properly take into account the unique training required by Pre-Admission Screeners. We recommend separate and distinct licenses for each of these services to clarify staff training requirements, team compositions, and to maintain fidelity to the services outlined.
Please see the recommendations/clarifications below per section of the draft.
12VAC35-111-10 - Definitions
Behavior Interventions: This definition does not provide clarity to know when this would apply. Due to the nature of an MCR and / or Emergency Services Pre-Screening, it cannot be presumed that assessors will consistently have access to assessment / records for services rendered outside of their own agency.
Community Based Crisis Stabilization: It is recommended that “Community Stabilization” should be used instead of “Community Based Crisis Stabilization” to be more consistent with DMAS language and service definitions. The following definition revision is recommended:
“Community-based crisis stabilization” means services that are short-term and designed to support an individual and their natural support system following contact with an initial crisis response service or as a diversion from a higher level of care. Providers deliver community-based crisis stabilization services in an individual’s natural environment whenever feasible; services provided in a setting that is not the person’s natural environment should be clinically justifiable and with reasons for such documented in the ISP and progress notes. Providers will make referrals and linkages to other community-based services with consent by the individual, which may include linking to specialized services such as those to address needs of individuals with developmental disabilities, children, and / or individuals needing support with substances. Provision of information and / or linkages to resource assistance programs and / or benefits a person may be eligible to receive may be provided if through this linkage a person’s socioeconomic stressors are likely to be reduced and potentially reduce likelihood of future crises. The goal of community based crisis stabilization services is to stabilize the individual within their community and support the individual and/or, as appropriate, the individual’s support system during the periods 1) between an initial mobile crisis response and entry into an established follow-up service at the appropriate level of care 2) as a transitional step-down from a higher level of care if the next level of care service is identified but not immediately available for access or 3) as a diversion from a higher level of care.”
Crisis Education and Prevention Plan (CEPP): It is recommended to adjust the language from “…experiencing a behavioral loss on control” to “behavioral crisis” as this language aligns closer with a person-centered approach.
Initial Assessment: It is unclear what is being clarified with the added language “an assessment is not a service”.
Initial Individualized Service Plan: The timeframe states 24 hours but we need to double-check that this is consistent in all specific services as we were thinking that CSU gives 48 hours to complete the crisis ISP. (see pg. 16)
Is this referring to the “Crisis ISP” that is referenced throughout the rest of the document? Recommend removing “Initial ISP” def and replacing with a clear definition for Crisis ISP.
12VAC35-111-20- Licenses
Pg.9:
The following licenses are recommended:
12VAC35 – 111-30 Service Descriptions
A – Crisis Receiving Centers: It is indicated that a nursing assessment is required. This contradicts the regulation in the Nursing Assessment section that indicates that nursing assessments are not required for Crisis Receiving Centers.
The regulation states that CRCs shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that the provider shall have a policy to address custody of children accompany parents but shall not be responsible for the children’s safety on the unit. Additionally, there should be a requirement for addressing children being assessed at the Crisis Receiving Center accompanied by their parents.
B – Community Based Crisis Stabilization: Combining multiple services under one license presents as very confusing in terms of what services are required to providers. Recommend breaking out service by service in the regulations as outlined above in the list of recommended licensed services.
It is suggested that “Emergency Services” and requirements of uniform pre-admission screening be clearly defined under a unique license to reflect the codified responsibilities and training / supervision requirements that are significantly unique to this public / mandated service.
C – Crisis Stabilization Units (RCSU): The regulation states that providers shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that the provider shall have a policy to address custody of children accompany parents but shall not be responsible for the children’s safety on the unit. Additionally, there should be a requirement for addressing children being assessed in a CSU to be accompanied by their parents or other legally designated substitute decision-maker (ie., DSS, kinship placement, etc).
D : The proposed regulation indicates that individuals cannot enter into “a REACH service” if they are actively using substances; however this is too broad as substances include nicotine, THC / CBD, etc. which do not / should not preclude someone from accessing REACH services. We DO strongly support the section related to not being able to support someone [at a REACH CTH] who is in active detox.
12VAC35 – 111- 40 Staffing
B: Community Based Crisis Stabilization Staffing for the community based crisis continuum services is complex and even more so in this section due to the bundling of multiple services under a singular license. It is recommended that these services are broken out under separate licenses to ensure accurate staffing requirements are addressed.
B1: Recommend to update to specify that the assessment is a crisis assessment and remove the CEPP language.
B2: This requirement is possibly a requirement of the VCC platform and is inappropriate to include in a licensing regulation.
B3 ii: Providers of mobile crisis response do not “dispatch” calls as this is a function of the regional hub and PRS/988. It is recommended to rephrase the regulation to read: “If a team response is recommended at dispatch…”
B3 ii – 6: It is recommended to change the language from QMHP-E to QMHP-T
C5 - A separate license is recommended for the REACH CTH; the MCO’s accept this definition for billing purposes. We would benefit from having licensing also recognize the REACH CTHs as a setting that provides crisis stabilization services. Recommend ensuring alignment with DOJ requirements.
D - It is recommended to not treat REACH differently than the rest of the crisis continuum when it comes to licensing regulations. The REACH Standards also, are not licensing regulations and therefore licensing regulations should not point readers / programs to this document which is not kept current and does not presently align with these draft regulations. Having separate guidance documents is not beneficial to community or providers. Additionally, REACH provides Community Crisis Stabilization, MCR and Crisis Therapeutic Home services, however Crisis Therapeutic Home regulations do not presently exist. It is further confusing for regulations to reference that some of the CTHs operate under RCSU licensing regulations; The REACH CTHs require their own CLEAR set of expectations to ensure consistency in operations, reduction in barriers to admission and consistency in systemic oversight statewide.
12VAC35 – 111 – 50 Initial Contacts
A -It is recommended that “initial contact” be defined in the definitions section.
This requirement is overly cumbersome administratively for inquiries that are not of a crisis nature. Please add clarifying language regarding intent OR recommend that these added reporting requirements be removed. Additionally, making service linkages or referrals would not be in scope depending on the type of services that is being contacted, unless a service is rendered.
12VAC35 – 111 – 60 Assessment
D: A crisis assessment is not the same thing as a comprehensive assessment due to the nature of the service and availability of records in a crisis.
It is recommended that the current DBHDS approved crisis assessment components align with the regulations as they currently do not match what is written here. The elements listed in the draft regulations are more closely aligned with a CNA than the crisis assessment.
F(10)b: For Crisis Stabilization Units and Community Based Crisis Stabilization, it is recommended that the regulations allow for providers to complete an addendum to the assessment; if a general crisis assessment or pre-screening is completed within the last 72 hours, an addendum should be allowed. Engaging an individual in an assessment process multiple times does not align with a person-centered or trauma-informed approach to care, particularly when a person is presenting as unstable due to crisis needs.
H: Record retention should not be included as it is already covered in the general regulations.
12VAC35 – 111 – 70 Safety plans and Crisis ISP
B: It is recommended that a singular CEPP be required for REACH services; A Safety Plan at the point of crisis assessment with a CEPP developed during the course of community crisis stabilization admissions or CTH admission would align more closely with the rest of the Crisis Continuum.
12VAC35 – 111 – 80 Safety plan and Crisis ISP requirements
D1 & D2: It is recommended to omit the underlined portions. Undue burden is placed on providers of short term, crisis services to make multiple attempts to obtain signatures beyond 48 hours. There is too much focus on documenting the attempts to obtain client signatures than on the clinical treatment they are in need of and receiving. Attempts are made to obtain signatures within the first 48 hours; documenting refusals and attempts during that timeframe should be sufficient as ongoing attempts beyond that period can damage the therapeutic relationship / trust and places focus on the wrong aspect of care.
12VAC35 – 111 – 90 Reassessments and Review of safety plans and Crisis ISPs
A: This section should clearly define what services this regulation applies to. It is recommended that this regulation does not apply to services that are for 72 hours or less.
12VAC35 – 111 – 100 Progress notes or other documentation
A: It is recommended that these regulations be further clarified or completely omitted from draft as it is redundant to section B which includes specifics of what should be included in progress notes.
B: Recommend removal of this item; general regs should suffice for progress note documentation
12VAC35 – 111 – 110 Discharge Planning
A: It appears the wrong code is referenced; the correct code should be 12VAC35-105-693. In general, the entire Discharge Planning section is unclear and contradictory in terms of what services are required to do and at what discharge planning steps.
B: It is unclear why a Crisis Receiving Center would not be required to provide discharge planning instructions and coordinate care with the rest of the service system on behalf of the individual served.
G: It is recommended that we document progress towards Crisis ISP instead of language related to “criteria for discharge” which adds additional burden for crisis services that supersedes what longer term services are providing.
12VAC35 – 111 -120 Written policies and procedures for crisis or emergency response; required elements
C4: It is recommended to remove “face sheet” terminology as the emergency medical information is present in different locations depending on the agency EHR.
12VAC35 – 111 - 130 Nursing assessment
A: This regulation does not align with DMAS regulations which require the nursing assessment at admission for any residential service and the 23-hour program. It was also noted previously that this regulation contradicts the regulation in 12VAC35-111-30. Service Descriptions (A).
C: The first sentence should be revised to “Prior to admission to (specify which service type)…”
D: Recommend removal of the first sentence as it is not needed or clarify as a “medical professional” shall conduct a nursing assessment.
It is recommended to clarify the type of service setting this requirement pertains to as resources vary by organization. It is also recommended to remove all language between “transfer to a more intensive level of care” and the last sentence of the paragraph. Nurses are not responsible for diagnosing underlying conditions.
H: It is recommended to add the qualifier “unless the provider has access to a shared electronic health record.”
12VAC35 – 111 – 140 Health Care Policy
B4: It’s unreasonable to expect CSUs and CTHs providing short term services to schedule “routine ongoing and follow up” medical and dental appointments; recommend revising to reflect need for this support to address “acute” medical and dental needs only.
C: General regs should cover the fall risk requirements; also, all services that admit a person to treatment are required to do a fall risk assessment so this is not inclusive of other services that are required to complete the fall risk assessment.
12 VAC35-111-230 Nutrition
B.1.b: Recommend remove the “provide methods to learn” from this requirement as this is unclear what all is being asked of the programs. Typically dietary needs of patients is specified on medical orders.
B.2.e: What is “periodically?” If this is not anticipated to be monitored / regulated, recommend removing.
12 VAC35-111-240 Beds or Recliners
G: Recommend removal of this item; tracking the number of days between laundering sheets is administratively burdensome. Physical environment / site visits should focus on whether the bedding is “clean” as specified in item A of this section.
12 VAC35-111-250 Bedrooms
B 1 & 2: Recommend language that indicates that for New services to be licensed they must meet these specified dimensions so that existing services that may not meet these specifications can be grandfathered in.
D: Same comment as B1&2 re: existing sites and grandfathering
E: Recommend “reduce risk” instead of “prevent” language since it’s impossible to fully prevent risk of harm to self by others
I: Clarify “provide separate sleeping areas” - does this mean separate wings or separate bedrooms.
J: This appears to be pulled directly from Children’s PRTF / Residential Treatment regs; question whether this is a needed requirement
12 VAC35-111-260 Physical environment
F: These water temps do not align with general physical env regs; recommend NOT attempting to duplicate sections of the general regs in each separate service regulations due to risk of inconsistencies and increased admin burden on not only licensing but the provider system.
M: Remove “prevent harm” language and replace with reduce risk language
O: This section was pulled from Children’s PRTF regs which is NOT the same level of care as Child CSU / CTH.
O.2 –Example It’s HIGHLY unusual for a CSU to have a Bathtub in their facilities
P1: Video cameras exist outside entrance in many cases; recommend revising language to be that the provider obtain written consent at admission instead of “Before admission”
12 VAC35-111-300 Floor plan and building modifications
What constitutes a building renovation especially for buildings where you incur a lot of damage. It’s a burden that every time you paint a wall, etc. that you need to submit this, especially when you require the building to be in good condition
12 VAC35-111-310 Lighting
Not consistent with other sections or chapters; please clarify if other sources are allowed when the electricity is out.
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General Comments |
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Combining multiple crisis services under one license presents as very confusing in terms of what services are required to providers. Recommend breaking out service by service in the regulations as outlined below.
It is suggested that “Emergency Services” and requirements of uniform pre-admission screening be clearly defined under a separate license to reflect the codified responsibilities, training, and supervision requirements of this mandated service. Further, prescreens used for crisis assessments in other crisis services (i.e., Mobile Crisis, Community Crisis Stabilization and 23 hour bed service) may be updated by Emergency Services when mandated, codified evaluation are needed. |
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Article 1. General Provisions |
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12VAC35-111-10 - Definitions |
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Behavior Interventions |
This definition does not provide clarity to know when this would apply. Due to the nature of an MCR and / or Emergency Services Pre-Screening, it cannot be presumed that assessors will consistently have access to assessment / records for services rendered outside of their own agency. |
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Comprehensive Assessment |
A crisis assessment is not the same thing as a comprehensive assessment due to the nature of the service and availability of records in a crisis.
It is recommended that the current DBHDS approved crisis assessment components align with the regulations as they currently do not match what is written here. The elements listed in the draft regulations are more closely aligned with a CNA than the crisis assessment. |
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Community Based Crisis Stabilization |
It is recommended that “Community Stabilization” should be used instead of “Community Based Crisis Stabilization” to be more consistent with DMAS language and service definitions. The following definition revision is recommended:
“Community-based crisis stabilization” means services that are short-term and designed to support an individual and their natural support system following contact with an initial crisis response service or as a diversion from a higher level of care. Providers deliver community-based crisis stabilization services in an individual’s natural environment whenever feasible; services provided in a setting that is not the person’s natural environment should be clinically justifiable and with reasons for such documented in the ISP and progress notes. Providers will make referrals and linkages to other community-based services with consent by the individual, which may include linking to specialized services such as those to address needs of individuals with developmental disabilities, children, and / or individuals needing support with substances. Provision of information and / or linkages to resource assistance programs and / or benefits a person may be eligible to receive may be provided if through this linkage a person’s socioeconomic stressors are likely to be reduced and potentially reduce likelihood of future crises. The goal of community based crisis stabilization services is to stabilize the individual within their community and support the individual and/or, as appropriate, the individual’s support system during the periods 1) between an initial mobile crisis response and entry into an established follow-up service at the appropriate level of care 2) as a transitional step-down from a higher level of care if the next level of care service is identified but not immediately available for access or 3) as a diversion from a higher level of care.” |
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Contracted Employee |
It is recommended to remove “employee” and use “contractor” language only. |
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Crisis Education and Prevention Plan (CEPP) |
It is recommended to adjust the language from “…experiencing a behavioral loss on control” to “behavioral crisis” as this language aligns closer with a person-centered approach. |
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Crisis Receiving Center |
. As CRC’s are developing, can other services be provided out of the CRC space (i.e., counseling, community based crisis stabilization) before 24/7 availability is reached? Would these then be covered under a “Crisis license?” |
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Initial Assessment |
It is unclear what is being clarified with the added language “an assessment is not a service”. |
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Initial Individualized Service Plan |
The timeframe states 24 hours but we need to double-check that this is consistent in all specific services as we were thinking that CSU gives 48 hours to complete the crisis ISP. (see pg. 16)
Is this referring to the “Crisis ISP” that is referenced throughout the rest of the document? Recommend removing “Initial ISP” def and replacing with a clear definition for Crisis ISP.
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12VAC35-111-20- Licenses |
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Pg.9 |
The following licenses are recommended:
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Pg.9 |
Community based stabilization says that it is also a mechanism by which pre-admission screening MAY be performed. Does this mean that preadmission screenings are/can be performed under both Mobile crisis billing AND Comm. Based stabilization services? If so, would licenses for both services then be required? |
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12VAC35 – 111-30 Service Descriptions |
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A – Crisis Receiving Centers |
It is indicated that a nursing assessment is required. This contradicts the regulation in the Nursing Assessment section that indicates that nursing assessments are not required for Crisis Receiving Centers.
Indicates that adults and children having physically separate areas and that if an adult has children and is being served with them present, we are able to provide for the safety of the accompanying children. Wondering if different rooms in the same area count as physically separate?
The regulation states that CRCs shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that the provider shall have a policy to address custody of children accompanying parents but shall not be responsible for the children’s safety on the unit. Additionally, there should be a requirement for addressing children being assessed at the Crisis Receiving Center accompanied by their parents. |
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B – Community Based Crisis Stabilization |
Combining multiple services under one license presents as very confusing in terms of what services are required to providers. Recommend breaking out service by service in the regulations as outlined above in the list of recommended licensed services.
It is suggested that “Emergency Services” and requirements of uniform pre-admission screening be clearly defined under a license that reflects the codified responsibilities, training and supervision requirements that are specific to this mandated service. |
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C – Crisis Stabilization Units (RCSU) |
The regulation states that providers shall provide safety to children accompanying parents receiving services. It is recommended that this language is adjusted to state that the provider shall have a policy to address custody of children accompany parents but shall not be responsible for the children’s safety on the unit. |
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D |
The proposed regulation indicates that individuals cannot enter into “a REACH service” if they are actively using substances; however, this is too broad as substances include nicotine, THC / CBD, etc. which do not / should not preclude someone from accessing REACH services. We DO strongly support the section related to not being able to support someone [at a REACH CTH] who is in active detox. |
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12VAC35 – 111- 40 Staffing |
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B – Community Based Crisis Stabilization |
Staffing for the community-based crisis continuum services is complex and even more so in this section due to the bundling of multiple services under a singular license. It is recommended that these services are broken out under separate licenses to ensure accurate staffing requirements are addressed. |
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B1 |
Recommend to update to specify that the assessment is a crisis assessment and remove the CEPP language. |
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B2 |
This requirement is possibly a requirement of the VCC platform and is inappropriate to include in a licensing regulation. Further, this has been true for mobile crisis response but NOT for Community based stabilization staffing requirement and they have not been monitored during encounters |
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B3 ii |
Providers of mobile crisis response provide a different service than Community based stabilization . The provision and number/type of services for mobile crisis and community based stabilization services are separate. Community based stabilization services are not dispatched. as this is a function of the regional hub and PRS/988. |
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B3 ii – 6 |
It is recommended to change the language from QMHP-E to QMHP-T
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C5 |
A separate license is recommended for the REACH CTH; the MCO’s accept this definition for billing purposes. We would benefit from having licensing also recognize the REACH CTHs as a setting that provides crisis stabilization services. Recommend ensuring alignment with DOJ requirements. |
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D |
It is recommended to not treat REACH differently than the rest of the crisis continuum when it comes to licensing regulations. The REACH Standards also, are not licensing regulations and therefore licensing regulations should not point readers / programs to this document which is not kept current and does not presently align with these draft regulations. Having separate guidance documents is not beneficial to community or providers. Additionally, REACH provides Community Crisis Stabilization, MCR and Crisis Therapeutic Home services, however Crisis Therapeutic Home regulations do not presently exist. It is further confusing for regulations to reference that some of the CTHs operate under RCSU licensing regulations; The REACH CTHs require their own CLEAR set of expectations to ensure consistency in operations, reduction in barriers to admission and consistency in systemic oversight statewide. |
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12VAC35 – 111 – 50 Initial Contacts |
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A |
It is recommended that “initial contact” be defined in the definitions section.
This requirement is overly cumbersome administratively for inquiries that are not of a crisis nature. Please add clarifying language regarding intent OR recommend that these added reporting requirements be removed. Additionally, making service linkages or referrals would not be in scope depending on the type of services that is being contacted, unless a service is rendered. |
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12VAC35 – 111 – 60 Assessment |
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D |
A crisis assessment is not the same thing as a comprehensive assessment due to the nature of the service and availability of records in a crisis.
It is recommended that the current DBHDS approved crisis assessment components align with the regulations as they currently do not match what is written here. The elements listed in the draft regulations are more closely aligned with a CNA than the crisis assessment. |
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F(10)b |
For Crisis Stabilization Units and Community Based Crisis Stabilization, it is recommended that the regulations allow for providers to complete an addendum to the assessment; if a general crisis assessment or pre-screening is completed within the last 72 hours, an addendum should be allowed. Engaging an individual in an assessment process multiple times does not align with a person-centered or trauma-informed approach to care, particularly when a person is presenting as unstable due to crisis needs. |
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H |
Record retention should not be included as it is already covered in the general regulations. |
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12VAC35 – 111 – 70 Safety plans and Crisis ISP |
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B |
It is recommended that a singular CEPP be required for REACH services; A Safety Plan at the point of crisis assessment with a CEPP developed during the course of community crisis stabilization admissions or CTH admission would align more closely with the rest of the Crisis Continuum. |
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12VAC35 – 111 – 80 Safety plan and Crisis ISP requirements |
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D1 & D2 |
It is recommended to omit the underlined portions. Undue burden is placed on providers of short term, crisis services to make multiple attempts to obtain signatures beyond 48 hours. There is too much focus on documenting the attempts to obtain client signatures than on the clinical treatment they are in need of and receiving. Attempts are made to obtain signatures within the first 48 hours; documenting refusals and attempts during that timeframe should be sufficient as ongoing attempts beyond that period can damage the therapeutic relationship / trust and places focus on the wrong aspect of care. |
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12VAC35 – 111 – 90 Reassessments and Review of safety plans and Crisis ISPs |
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A |
This section should clearly define what services this regulation applies to. It is recommended that this regulation does not apply to services that are for 72 hours or less. |
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12VAC35 – 111 – 100 Progress notes or other documentation |
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A |
It is recommended that these regulations be further clarified or completely omitted from draft as it is redundant to section B which includes specifics of what should be included in progress notes. |
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B |
Recommend removal of this item; general regs should suffice for progress note documentation |
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12VAC35 – 111 – 110 Discharge Planning |
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A |
It appears the wrong code is referenced; the correct code should be 12VAC35-105-693. In general, the entire Discharge Planning section is unclear and contradictory in terms of what services are required to do and at what discharge planning steps. |
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B |
It is unclear why a Crisis Receiving Center would not be required to provide discharge planning instructions and coordinate care with the rest of the service system on behalf of the individual served. |
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G |
It is recommended that we document progress towards Crisis ISP instead of language related to “criteria for discharge” which adds additional burden for crisis services that supersedes what longer term services are providing. |
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12VAC35 – 111 -120 Written policies and procedures for crisis or emergency response; required elements |
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C4 |
It is recommended to remove “face sheet” terminology as the emergency medical information is present in different locations depending on the agency EHR. |
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CommentID: 222301
3/13/24 7:26 pm
Commenter:
Shari Medley, PMHNP-BC
Staffing requirements 12VAC35-111-40. Staffing. A. Crisis receiving centers shall meet the following staffing requirements:
There needs to be clarification on this standard. You are "grouping" all Nurse Practitioners and there is a difference. Psychiatric Mental Health Nurse Practitioners do the same as a Psychiatrist. This is a speciality, just as if you were going to see a cardiologist for your heart. You will have a problem with nurse practitioners practicing outside of their scope. Yes, they can treat minor things like anxiety and depression but not major psychiatric disorders. They can only do basic evaluations. We take a completely different clinical paths and you want to make sure these patients are getting the best psychiatric care needed. Thank you for allowing me the opportunity to give feedback on this matter.
CommentID: 222303
3/14/24 11:17 am
Commenter:
Gail McLemore
CIBH feedback related Crisis Services Specific Chapter
CommentID: 222307
3/14/24 1:40 pm
Commenter:
Anonymous
Many concerns with proposed changes The Region 5 Crisis Taskforce believes that lumping Crisis Stabilization, Mobile Crisis Response, REACH, and Emergency Services into a single license there is a general lack of clarity and the context in which each service is provided is lost. Each service has a defined purpose across the crisis continuum and in some cases such as pre-admission screening, it creates blurred boundaries of public and private responsibilities outlined in Virginia Code and does not properly take into account the unique training required by Pre-Admission Screeners. We recommend separate and distinct licenses for each of these services to clarify staff training requirements, team compositions, and to maintain fidelity to the services outlined. Specific Comments:
CommentID: 222308
3/14/24 2:35 pm
Commenter:
Brandon Rodgers
Recommended Changes Overall: By lumping Crisis Stabilization, Mobile Crisis Response, REACH, and Emergency Services into a single license there is a general lack of clarity and the context in which each service is provided is lost. Each service has a defined purpose across the crisis continuum and in some cases such as pre-admission screening, it creates blurred boundaries of public and private responsibilities outlined in Virginia Code and does not properly take into account the unique training required by Pre-Admission Screeners. We recommend separate and distinct licenses for each of these services to clarify staff training requirements, team compositions, and to maintain fidelity to the services outlined.
CommentID: 222309
3/14/24 2:45 pm
Commenter:
Anonymous
Emergency Services There are clear definitions of service expectations and goals for CRC, CSU, REACH and community based crisis stabilization; however there are no clear service expectations or goals for Emergency Services. If you read the code, as presented, it could leave the impression that Emergency Services, which is a CSB services, is only meant to "serve as a mechanism" for community based crisis stabilization and to assist with discharge planning from state facility. Furthermore, Emergency Services is a restrictive services as it can lead to involuntary hospitalization under civil commitment and are normally the first points of contact for MOT. I would advocate for a separate license for Emergency Services with additional and distinct expectations and goals for this services as well. Although, Emergency Services provides an assessment, which as the code is written states "assessment is not a service". In the function of Emergency Services in the state of Virginia, this entity does in fact provide a service despite the formal product being an assessment. There is also redundancy in assessment requirements, it maybe helpful for accuracy and implementation of one state crisis assessment form being used. Also, with regards to discharge planning, all crisis services have a responsibility to assist the consumer with care coordination, which is the hallmark of discharge planning.
CommentID: 222310
3/14/24 10:49 pm
Commenter:
St John
Separate and distinct licenses for crisis services
I also recommend separate and distinct licenses for the crisis services listed below in order to clarify staff training requirements, team compositions, and to maintain fidelity to the services outlined. Specific Comments: 1. Pg. 9 Paragraph 1: Recommend the following licenses: a. Crisis Receiving Center b. Community-based Stabilization c. Mobile Crisis Response d. Emergency Services e. REACH Mobile Response and Stabilization f. REACH Crisis Therapeutic Home g. Crisis Stabilization Unit 2. Pg. 9 Paragraph 3: Pre-admission screening and Emergency Services should be properly defined under a unique license to reflect the codified responsibilities and training unique to this service. Thank you
CommentID: 222311
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