General, Top Three Concerns:

1. New requirement for ACT teams to directly respond and be the first-line crisis evaluator for PACT clients 24/7. We are advocating the current regulation stands for 24/7 response; it allows for coordinating outside the team for coverage. More justification below.

2. The use of QMHP and LMHP in several places, versus also allowing for LMHP-Es and QMHP-Es. We are advocating that any time an LMHP or QMHP is required, that Es are also eligible considering work force shortages.

3. Some requirements seem better suited for a fidelity measures versus regulation. This may help smaller CSBs, or those in the highest workforce shortage areas, to still operate ACT to the best of their ability. This would be in line with the new per diem proposals related to fidelity levels.

Crisis Response:

• Concerned some regulations and code need more consistency; will the administrative Code of Virginia also change?

• Recommend keep D. This makes sense and consistent with Virginia Code. The practice has worked well over many years of providing PACT and ICT around the state.

D. The ICT or PACT ACT team shall make crisis services directly available 24 hours a day but may arrange coverage through another crisis services provider if the team coordinates with the crisis services provider daily.

• Recommend strike changes to E.  As long as clients have access to competent professionals for coverage 24/7, it does not need to be required that ACT team staff are also the 24/7 first line evaluators. Accomplishing this with teams as small as ACT is virtually impossible. This requirement will increase staff turnover which is a detrimental to clients. This will be difficult for many CSBs to make happen. This could be a high fidelity measure versus regulation. T

This can also be construed to mean ACT teams need pre-screeners to do and appropriate crisis evaluation.  Adding a crisis evaluator pre-screeners to ACT, would not cover 24/7 and may result in higher hospitalization rates. New Mobile Crisis services may be better suited to stabilize a crisis without hospitalization and coordinate with ACT.

E. The PACT ACT team shall operate an after-hours on-call system and shall be available to individuals by telephone or in person have 24-hour responsibility for directly responding to psychiatric crises, including meeting the following criteria:

1. The team shall be available to individuals in crisis 24 hours per day, seven days per week, including in person when needed as determined by the team;

2. The team shall be the first-line crisis evaluator and responder for individuals served by the team; and

3. The team shall have access to the practical, individualized crisis plans developed to help them address crises for each individual receiving services.