The current proposed regulations place the existing Crisis Stabilization Units and growing Crisis Receiving Centers (23 hour observation) at risk by eliminating the ability for these critical programs to generate Medicaid revenue upon which they must rely for sustainability. Of primary concern are the requirements that these programs have 24/7 Registered Nurse (RN) staffing at a time when the America Nursing Association has asked federal agencies to designate the nursing shortage in the US as a national emergency. There simply are not enough RNs, particularly in rural areas of the state, to meet this need and to recruit these RNs, these services would potentially be pulling resources from our medical hospitals and providers who desperately need them due to the on-going pandemic and national state of emergency. Without the Crisis Stabilization Units in our communities many individuals will not be able to access the necessary care at a time when Virginia’s safety net, the state hospitals are unavailable due in part to the very workforce shortages that these programs will now face related to nursing. A grace period of 9 to 12 months to meet the nursing requirements in these regulations or allowance to use Licensed Professional Nurses without an RN on site is a more reasonable expectation.
