My understanding of the 12/1/21 updates will have deleterious impact on local resources that are critically important for responding to mental health emergencies in the New River Valley.  In a period where all sectors are facing understaffing, it is not the time to elevate staffing regulations, particularly for nurses.  The impact of well-meaning regulations would be that some of our most used and needed resources in rural SWV would have to close, thus increasing demand at other resources far from our locality.  Students of Virginia Tech are my clients, and those without health insurance or transportation or family support will be at severe disadvantage when their mental health becomes an emergency.  We cannot reduce the number of crisis beds in this area, and we cannot reduce the ability of non-profits such as NRVCS to serve impoverished and undersupported individuals.  Please remove updates on staffing requirements at this time, and if they must be added, please do so in a more gradual time frame when every sector across the economy is not already understaffed.  This is not the time for these changes.  Thank you for your consideration.