Considering the hospital bed shortage, RCSUs cannot afford to close.  They are needed now more than ever.  Given the proposed regulation changes, it is likely many RCSUs will become inoperable as the regulations are unrealistic, cause an overwhelming administrative burden, and could negatively impact our clients by limiting services and not treating each member individually, in a person-centered manner . Please consider the following comments.

1. None of the Crisis Services should REQUIRE a referral from the Crisis Hotline as it creates a barrier by limiting options for our members to receive services.
2.  For staffing reasons, it is unrealistic to have a Psych Eval completed at the time of admission.  This is especially true for small or rural RCSUs.  Also, the time of admission might not be an appropriate time for the client to have another evaluation completed, and person-centered delivery of services is crucial.  It makes more sense for the Psych Eval to be completed within 72 hours (or at least 24 hours, at a minimum) in order not to overwhelm the individuals we serve.
3. Is the CEPP in addition to the Tx Plan, or does it replace it?  The requirements of the CEPP are vague in the new regulations and need clarification. The CEPP is lengthy and unnecessary for acute, short-term services. It should not replace the Tx Plan. Also, a Tx Plan can be completed by a QMHP, where the CEPP requires completion by an LMHP or LMHP-type.  Once again, for staffing reasons in a small or rural RCSU, the CEPP is an administrative burden and the Tx Plan should be sufficient.
4. All RCSUs will have difficulty staffing an RN on-site 24/7, especially the small and rural ones.  To avoid making an RCSU inoperable due to this staffing challenge, a recommendation would be to have RNs or LPNs 24/7. When an LPN is working directly under an RN, have that RN available either on-site or by telephone.