There are a number of places in the draft manual where requirements do not seem to acknowledge best practices for those served by this part of the crisis continuum, nor are they reflective of current realities and processes that support people in these services.  Concerns are predominantly related to the lack of clarity about the use of the CEPP, 24/7 on-site nursing requirements at CSUs, and the psychiatric evaluation being done "at the time of admission."   Lastly, the requirement that  calls be routed from/to the crisis hotlines is untimely. 

The use of the CEPP needs further clarification. 

 This is required for multiple services. Does the CEPP replace the Treatment Plan at the CSU   or is it in addition to it? Both are mentioned in several sections. And what are the qualification requirements of the staff who are to complete them? What are DBHDS required components for the CEPP?  The current CEPP used by REACH is excessively cumbersome  and not well suited for those being served in CSUs and acute MH intervention and stabilization services.   Recommend to clarify if the CEPP replaces the Treatment Plan or is in addition to it, confirm what are the required elements for the CEPP, and confirm the credentials of the staff who completes it.  For more acute, shorter term services,  such as community stabilization and 23 hour observation, this document may be unnecessary.  

The 24/7 on-site nursing requirement.

This is a change from previous, as on-site nursing was not required for MH Crisis Stabilization. Requiring a RN to be present at all times will present significant challenges for recruitment and staffing. Recommend that language be updated to reflect that nursing services be provided by a RN, or a LPN working directly under an RN, who is either present on the unit or available by telephone. 

The requirement for psychiatric assessment at time of admission.

Currently, psychiatric evaluation is required to be completed within 24 hours of admission.  Late day or evening admissions will often not be able to be completed before midnight. Consider revising the statement "at the time of admission" to allow for a 24-hour period, or longer depending on if they are stepping down from a higher level of care. It does not seem client-centered or trauma informed to have clients sit through multiple assessments at the time of admissions if there is recent information available.   

Referrals from/to the Crisis Hotline.

At this time, this requirement creates barriers to service.  It is contrary to the current processes, and without further infrastructure, agreements, and process clarification it has the grave potential to allow for miscommunication and furthering unnecessary delays in the process.  The language and processes of call centers will need need further development  before this requirement should be enacted.