Although I appreciate the effort to strengthen staffing, the proposed DMAS changes during a labor shortage for mental health providers, nursing staff, and psychiatrist may to led to closure of valuable crisis stabilization units, crisis centers, and therefore reduce options for individuals in need of support. Inpatient mental health facilities are already struggling to manage the demand for emergency mental health care.
Please delay implementation of the regulations requiring LPN on site as well as the requirement of psychiatry evaluation at the time of admission. Please clarify how a regional crisis hotline will function for individuals on site with a client in need and not able to directly connect to their local emergency provider.