12VAC35-111-40. Staffing.

A. Crisis receiving centers shall meet the following staffing requirements:

1. A licensed psychiatrist or nurse practitioner shall be available to the program 24/7 either in person or via telemedicine;

There needs to be clarification on this standard. You are "grouping" all Nurse Practitioners and there is a difference. Psychiatric Mental Health Nurse Practitioners do the same as a Psychiatrist. This is a speciality, just as if you were going to see a cardiologist for your heart. You will have a problem with nurse practitioners practicing outside of their scope. Yes, they can treat minor things like anxiety and depression but not major psychiatric disorders. They can only do basic evaluations. We take a completely different clinical paths and you want to make sure these patients are getting the best psychiatric care needed.

Thank you for allowing me the opportunity to give feedback on this matter.