Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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7/17/22  12:50 pm
Commenter: Amy Erb, RBHA

RCSU/Nursing requirements

I support comments that speak to eliminating the requirement for 24/7 nursing for CSUs, especially for smaller units and those that serve youth, as the need for this level of care has not been demonstrated in most of these settings; the use of medication and first-aid trained staff with access to on-call nursing/other emergent care responses that can fulfill a similar need and has been demonstrated as successful for these programs; and the severe shortage of nurses in the Commonwealth will not soon be alleviated. The cost of 24/7 nursing in relation to the per diem reimbursement is also cost prohibitive, especially for smaller units.

CommentID: 122660