I support amending 12VAC35-105-1840(C)(3) to allow crisis stabilization units to base nursing coverage on an individualized services plan (ISP)-driven, two-tier nursing model.

Since current regulations requiring in-person nursing services 24 hours a day, 7 days a week for all clients result in significant financial losses for providers, as the combined staffing costs of registered nurses, licensed practical nurses, and other behavioral health professionals exceed the DMAS daily reimbursement rate. The unsustainable gap risks reducing access to vital crisis stabilization services for individuals and families in need across Virginia. Adopting an ISP-driven, two-tier nursing model would align the Board’s regulations with established DMAS standards and ensure both safety and fiscal sustainability. It matches nursing coverage to the actual clinical needs of each client, rather than imposing a uniform standard on all admissions, making better use of limited resources without compromising quality of care. I would urge the Board to consider this amendment to preserve essential crisis stabilization programs and maintain timely, effective access to care throughout the Commonwealth.