Please consider requiring an RST Meeting to occur within 2 business days of receiving the emergency meeting request when an emergency admission to a training facility is requested. The draft currently does not set a requirement for how long this step in the process could take. 

Recommend making RST recommendations be provided in writing within 1 business day of the emergency RST meeting taking place.

"In the event that admission is still necessary, the CSB shall consult with the department..." Recommend putting a position title here so that the CSB knows from whom specifically they are to request consultation with at the department, for both types of admission requests - voluntary and involuntary.

Recommend that Admission decisions be required to be made for emergency admission requests within 5 business days, rather than 10; same with reconsideration request reviews / responses by the Commissioner. Emergency situations where a fragile person is unable to be maintained safely in the community are unable to wait weeks upon weeks.

Decreasing the timeframe for the training center director’s decision from 10 business days to 5 business days would significantly enhance the efficiency of the admission process. This change is especially important for individuals in crisis with intellectual or developmental disabilities who need timely interventions and support. These individuals often face a system of care that is already overwhelmed and under-resourced by the time they reach the crisis stage. Many are at risk of homelessness, and reducing the waiting time would help alleviate anxiety and uncertainty for the individuals, their families, and support coordinators—who are all facing unprecedented challenges due to resource shortages and staff turnover.

In addition, the timeframe for the director or designee to notify the CSB of the decision regarding an emergency admission is changed from 24 to 72 hours. I would propose to hold the timeframe at 24 hours, as the CSB is seeking an emergency admission.

Moreover, an expedited decision-making process would allow for more timely responses to urgent needs, potentially preventing further crises and minimizing delays in behavioral, medical, and mental health interventions.

Regional Support Team (RST) Meeting Timeline

Additionally, the provided regulations do not specify a timeframe for scheduling the Regional Support Team (RST) meeting. Therefore, we recommend that the RST meeting be required to occur within 2 business days of receiving an emergency meeting request. In many crisis situations, community resources have already been exhausted, and the individual urgently requires substantial medical, behavioral, and mental health support. Often, these supports are necessary to ensure the safety of both the individual and the broader community.

The 2-Day Timeframe is Essential for the Following Reasons:

1. Urgent Need: Individuals in crisis need immediate attention. Delaying intervention beyond 2 days could worsen their condition and result in harmful outcomes.
2. Prevention of Unnecessary Institutionalization: A prompt RST meeting can help quickly identify community-based alternatives to institutional care, preventing unnecessary institutionalization.
3. Strained Resources: Efficient scheduling and resource allocation would reduce the strain on community services and the CSB, which have already exhausted their available resources.
4. Improved Outcomes: Timely intervention in a crisis situation is more likely to be effective and reduce the severity of the crisis, leading to better overall outcomes for the individual.

I am reiterating the remarks by Jennifer Eckert, as we worked on our response together.

Application B.5

Decreasing the timeframe for the training center director’s decision from 10 business days to 5 business days would significantly enhance the efficiency of the admission process. This change is especially important for individuals in crisis with intellectual or developmental disabilities who need timely interventions and support. These individuals often face a system of care that is already overwhelmed and under-resourced by the time they reach the crisis stage. Many are at risk of homelessness, and reducing the waiting time would help alleviate anxiety and uncertainty for the individuals, their families, and support coordinators—who are all facing unprecedented challenges due to resource shortages and staff turnover.

Moreover, an expedited decision-making process would allow for more timely responses to urgent needs, potentially preventing further crises and minimizing delays in behavioral, medical, and mental health interventions.

Regional Support Team (RST) Meeting Timeline

Additionally, the provided regulations do not specify a timeframe for scheduling the Regional Support Team (RST) meeting. Therefore, we recommend that the RST meeting be required to occur within 2 business days of receiving an emergency meeting request. In many crisis situations, community resources have already been exhausted, and the individual urgently requires substantial medical, behavioral, and mental health support. Often, these supports are necessary to ensure the safety of both the individual and the broader community.

The 2-Day Timeframe is Essential for the Following Reasons:

1. Urgent Need: Individuals in crisis need immediate attention. Delaying intervention beyond 2 days could worsen their condition and result in harmful outcomes.
2. Prevention of Unnecessary Institutionalization: A prompt RST meeting can help quickly identify community-based alternatives to institutional care, preventing unnecessary institutionalization.
3. Strained Resources: Efficient scheduling and resource allocation would reduce the strain on community services and the CSB, which have already exhausted their available resources.
4. Improved Outcomes: Timely intervention in a crisis situation is more likely to be effective and reduce the severity of the crisis, leading to better overall outcomes for the individual.

thank you for offering this opportunity to provide public comment and for taking into consideration the feedback provided.