1. New requirements related to after hours and the requirement that PACT teams directly respond for clients 24/7 places additional burden on small teams and will likely increase staff turnover which has negative impacts on the program, agency, and most importantly individuals being served.  We would like for the requirement of 24/7 response to be left as is which allows for additional flexibility for PACT to coordinate with other providers to ensure client needs are met. Current regulation: “D. The ICT or 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.”

2. Please consider allowing LMHP-Es and QMHP-Es under supervision in the program in regulation where requirement is specified for LMHPs and QMHPs. We have faced challenges recruiting for PACT programs as it is. CSBs face workforce shortages and LMHP-Es and QMHP-Es should also be considered eligible for work in the program.

3. Request that the QMHP requirement for ICT Peer Specialist be removed. Peer training is a more appropriate skill set for this staff member.

4. Recommend allowing for general Nurse Practitioner be considered as eligible to provide psychiatric medication management services to the program instead of “Psychiatric Nurse Practitioner.” Psychiatric nurse practitioners are rare.

5. Will Code of Virginia also be updated to be consistent with new regulations?

6. The language surrounding ACT and ICT is confusing and does not appear to be consistent throughout the regulation.

7. Many of the regulation requirements would impact the ability of smaller CSBs to effectively implement ACT program. Some requirements seem to fit in best with fidelity measures rather than a requirement in regulation.