Virginia Regulatory Town Hall
Department of Behavioral Health and Developmental Services
State Board of Behavioral Health and Developmental Services
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9/30/22  4:47 pm
Commenter: Mindy Carlin, Executive Director, VACBP

12VAC35-109-440. Substance abuse outpatient service program criteria

The following outlines our input in this section:

For reasons consistent with our other comments, we suggest removing (2) of this section, which reads, “Ensure emergency services are available by telephone 24 hours a day, 7 days a week," given this is not a crisis-level service and being available in this way could be a significant challenge for providers. There are also liability and risk concerns related to this requirement among licensed mental health professionals. 

CommentID: 182582