I am opposed to this amendment as conflating private providers and CSB prescreeners represents a significant conflict of interest, undo hardship on CSB's to have private providers conducting prescreens as  CSB designee's without the oversight and administrative authority CSBs currently have over staff employed at the boards/behavioral health authority, and the training and credentialing requirements etc. that CSBs currently meet to have well qualified prescreeners on their teams, as a start.  Also the MARCUS Alert legislation by no means requires private providers who are a part of the Crisis continuum to also be prescreeners. The goal of the Marcus Alert, STEP-VA Crisis step, and the implementation of the regional call centers is to provide services in the community and if the crisis requires a prescreen,  the CSB will conduct the prescreen if community based crisis interventions are unsuccessful or do not met the client's level of acuity.  

The amendment also does not speak to the intense work that goes into the civil commitment process including: bed searching for involuntary individuals, petitioning for TDO's, alternative transportation and other processes, facilitating and/or participating in hearings, facilitating MOT when ordered, liaison duties if the individual is placed at a state facility, and access to regional/ DBHDS funds to obtain certain funding and program resources.  As Virginia moves towards a more comprehensive crisis system all providers both public and private are needed to have this goal actualized.  However, data has proven,  CSBs are able to decrease unnecessary hospitalizations by following the stringent civil commitment laws, DBHDS polices, and other guidance that CSB prescreeners adhere to while providing emergency services regardless of an individuals ability to pay or specific to MCO/insurance carrier.