The following outlines our input in this section:

• In (3) of this section, we suggest removing the requirement that consultation in case of emergency be required, “by telephone 24 hours a day, 7 days a week when the treatment program is not in session,” 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.