I agree with all other comments listed. Specifically:
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.
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.
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.
