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.