Thank you for the opportunity to provide comments on the proposed MCR Best Practices. The Arc of Virginia promotes and protects the human rights of people with developmental disabilities and actively supports their full inclusion and participation in the community throughout their lifetimes. To help ensure these best practices promote the dignity, safety, and inclusion of people with developmental disabilities, we offer the following recommendations:

Add the bolded text in quotes: MCR aims to reduce the utilization of hospitals “or other forms of institutionalization” when there are other options available, however an individual presenting signs of significant risk may require hospitalization.

Add the bolded text in quotes: While MCR can be provided for up to 72 hours, it is best practice, when possible, to handoff as soon as practical to a community-based stabilization team or other service best designed to meet  the individual's needs. “Practical can be defined as when the MCR has identified appropriate community-based supports that meet the individual’s needs.” This is especially true for youth and individuals with developmental disabilities.

Clarify Concerns About “Fast Response Times” and Avoid Penalizing Providers Who Respond Quickly: We understand the Department’s concern about some providers “self-referring”—calling mobile crisis for a person who is already in their care and then accepting the dispatch themselves. This can make it look like a mobile crisis response occurred when it did not. However, the guidance says response times “should not consistently occur in less than one minute.” This wording is confusing and may unintentionally punish providers who are simply being efficient. We recommend updating this section to:

• Clearly explain that the concern is about inappropriate self-referrals, not fast response times

• Give examples of when self-referral is not allowed and when quick dispatch acceptance is appropriate

• Make sure providers do not feel discouraged from responding quickly to real crisis calls

• Base quality reviews on whether the process was used correctly, not on a time threshold alone

• Clearer language will prevent misuse while still protecting providers who respond promptly and appropriately.

MCR providers will have an active, DBHDS-approved memorandum of understanding (MOU) or contractual agreement with the regional crisis hubs and update it as necessary. Providers must meet the criteria set forth by regional MOU requirements, however not every provider will receive one.

• Clarify the process and criteria for determining whether a provider receives an MOU or a contractual agreement, and ensure that all providers have a timely path to obtain the required documentation. Specify that providers must meet the criteria outlined in whichever document they receive.

Providers must have an active MOU before obtaining a DMAS enrollment.

• This qualification reads as incomplete given the previous qualification. If not every provider will receive an MOU, this should include contractual agreements with the regional crisis hubs.

Services may not be provided to more than one individual at a time, even in situations where a team of employees are present.

• Define “at a time” clearly. For instances when two individuals are in crisis at the same time in the same location, detail how a MCR team may respond. For example, would it be acceptable to respond to a call involving two individuals if the individuals a separated?

We have also read the comments from Endependence Center of Northern Virginia, and support their recommendations.

Thank you again for the opportunity to provide comments on the proposed MCR Best Practices,  and please let us know if you have any questions about the recommendations above!