VB DHS has concerns regarding the addition of an expectation that ACT teams “shall be the first-line crisis evaluator and responder”.  Although ACT teams are expected to have staff members available for assistance in crises at all times, this on-call access is best suited to help with de-escalation and connection to crisis evaluators when de-escalation is unsuccessful.  ACT staff are also available to Emergency Services pre-screeners to help coordinate care.  Inclusions of a requirement for a first-line crisis evaluator blurs the boundary between two Licensed services – ACT and Emergency Services.  Per state legislation, Emergency Services evaluations must be provided by Community Services Boards and those staff members must have specific training.  Therefore, it falls beyond the purview of any ACT provider to assume this role.  The current language of making crisis services directly available 24 hours a day sufficiently articulates that a high level of responsiveness is expected.  Removal of the option to coordinate coverage via another crisis provider may make it challenging to provide this level of responsiveness is rural localities, ultimately having a negative impact on the availability of this service.  In addition to the role-diffusion, there are concerns regarding the impact of additional requirements to members of ACT teams.  Requirements to provide a higher level frequency and intensity of crisis services will contribute staffing shortages, both in the short-term (as staff members can only work a certain number of hours safety) and in the long-run (due to increased staff turnover), again detracting from the overall ability to provide this valuable service.

We also advocate to have LMHP-Es specifically referenced as being able to provide ACT services.  Although Residents in Psychology, Residents in Counseling, and Social Work Supervisees inherently meet the requirements of being a QMHP, omission of this qualification will result in increased, unnecessary financial and administrative burdens – applicants will need to register with their Licensing Board for their supervision and with the Board of Counseling as a QMHP-A; the Board of Counseling will have to process these duplicative applications.