In regards to Page 27 (23 Hour Observation) and Page 35 (Residential Crisis Stabilization) there are staffing requirements for an RN to be onsite supervising an LPN at all times.  While it is indeed best practice, given workforce shortages across the Commonwealth it is unrealistic to ensure onsite coverage by an RN 24/7 and likely would decrease the availability of qualified providers.  In light of this, an LPN practicing onsite may have capacity to reach an on call RN, NP, PA, or MD for clinical guidance.

In regards to Page 32 (Residential Crisis Stabilization) the requirement of 24/7 nursing, while best practice again is at risk of disqualifying providers during the current pandemic related workforce shortage.  Alternatively medication technicians trained in an approved course by DBHDS could assist with medication administration and nursing services be available on call or as needed for the level of care of individuals on the unit until staffing levels can stabilize post pandemic.