In consultation with local mental health professionals and after reviewing proposed documents, it appears that some of the regulations have potential outcomes that may negatively impact regions of Virginia. 

Key areas of concern include:

-The proposed regulations potentially create obstacles for local resources to bill for certain services which impacts their funding.  Reduced funding (or access to funds) equals reduced services available to the community. 

-It has been suggested that the proposed regulations may result in the reduction of available bed space for certain regions.  Under no circumstance should the implementation of regulations result in the loss of bed space for consumers of mental health services.  There is a current shortage which should not be knowingly exacerbated.

-The requirement of having on-site RN's 24/7 may force existing crisis centers/stabilization units with medical plans to reduce hours of operation if they cannot fill staffing requirements.  Forward progress in mental health should not be at the expense of existing services.  

I would encourage this regulatory body to work closely with Community Service Boards and stakeholder groups within all of the regions to determine the actual, negative consequences of imposing these regulations and mitigate them prior to implementation.  Virginia is in a very delicate moment with its decisions about mental health.  We should not take steps forward if there is information existing that suggests we will negatively impact our citizens in the process.