While I appreciate the intentions of proposing changes to standardize care without a gradual timeframe these changes would further add strain on an already strained mental health care system. Implementing these changes in the midst of labor shortage for mental health providers, nursing staff, and psychiatry will lead to minimal to no access for treatment and could cause further harm of individuals and potentially communities who are already struggling. Many of clients I provide care for do not have financial means, health insurance, or family support within the United States. Without the option of local crisis stabilization units and direct access to local community service board crisis clinicians, clients already facing barriers will be experience further distress and harm. Please reconsider the requirement for an RN/LPN on site, psychiatric evaluation at the time of admissions, and retaining direct access to local emergency services clinicians who are familiar with regional resources.