Virginia Beach Behavioral Health and Developmental Services has concerns regarding Mr. Vaughn’s petition. While we recognize his goal of improving the flow of the assessment process, we believe the negative impacts outweigh the benefits. Clinically, this would work against the aims of the new crisis continuum of care as it would likely increase the number of TDOs and would increase, vs. decrease, the need to involve law enforcement officials in the process. Specifically, if an individual located in the community and a Mobile Crisis Response staff member supports a TDO, who would provide security and monitor the individual while the crisis worker looks for a TDO bed?

Allowing this change would also create an undue burden and risk to the CSB system. This process would have an unknown number of people employed by an unknown number of providers considered to be designees of a CSB. Which CSB? For example, if an agency provides Mobile Crisis Response to residents of Chesapeake, Norfolk, and Virginia Beach, are their employees considered designees of each CSB? When employees of an independent agency are considered designees of a CSB, there are numerous complexities, related to matters such as clinical oversight, training and personnel records, ownership of clinical documentation, reporting of incidents (i.e., reporting in CHRIS) and risk management, and state reporting requirements unique to the CSBs. Providers of Developmental Services Case Management have already learned the complexities involved in attempting to do this. These would be magnified when working within the context of crisis services. We respectful request that this petition not be supported.