Virginia Regulatory Town Hall
Agency
Department of Behavioral Health and Developmental Services
 
Board
State Board of Behavioral Health and Developmental Services
 
chapter
Rules and Regulations For Licensing Providers by the Department of Behavioral Health and Developmental Services [12 VAC 35 ‑ 105]
Action Amendments to align with enhanced behavioral health services
Stage Emergency/NOIRA
Comment Period Ended on 3/3/2021
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2/24/21  5:55 pm
Commenter: Connie Vatsa, H-NNCSB

Proposed ACT regulation changes
 

For the co-occurring disorder specialist the qualifications are LMHP, QMHP, or CSAC. I thought I recalled during the workshops that LMHP types (LMHP-E, RIC) would also be allowable in this position. Not all LMHP types maintain their QMHP registration. I can't imagine why if a QMHP would be qualified an LMHP type would not qualify as well. 

The crisis coverage language contradicts itself. Under D it says an ACT team may arrange coverage through another crisis provider to make coverage available 24/7 but E2 says the team shall be the first line crisis evaluator. Requiring the team to be the first line crisis evaluator is going to result in significant increase in staffing resource need. Given the fact that the grant allocation is not increasing this would be a significant burden that I am not sure we could meet with our current financial resources. We currently arrange coverage with our emergency services department after hours and that staff has the number for the team on-call. This has worked well and ES routinely calls our on-call. 

CommentID: 97257