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Virginia Regulatory Town Hall
Department of Medical Assistance Services
Board of Medical Assistance Services
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11/5/21  5:24 pm
Commenter: Barbara Brady, HRCSB

Administrative Services Director

As noted in a majority of comments, a number of these proposed regulations will have a negative impact on services you want us to provide. However, there are aspects of the regulations that could be viable with minor tweaking. Some of these are:

  • The Board of Nursing regulations regarding LPNs require an RN to oversee an LPN's work, however they do not stipulate the RN needs to be on site. Changing this proposed language to remove the on site stipulation would help staffing requirements significantly. 
  • Changing this requirement in the middle of an unprecedented labor shortage, including both nurses and crisis mental health staff, isn't viable. We can hardly find required staff now and these changes will makes these challenge all but impossible.
  • Proposing that an evaluation happen "same day" instead of "within a 24-hour period" isn't realistic when a client is in crisis, nor is it sensitive to their needs. As service providers, it's important that we have some flexibility to determine what a client in crisis can handle in terms of administrative process. Nothing is lost by letting someone rest first.
  • Hopefully, the Crisis Call Center will be a successful effort that is fully staffed, fully functional and working in close collaboration with local efforts. However, requiring referrals through it, ignoring the critical role (and familiarity) of existing crisis services, isn't realistic. More thought needs to be given to how these efforts collaborate and in the meantime, regulations should reflect more flexibility.
  • Finally, NOT changing some of these key elements but following up with FAQs or follow-on guidance, is insufficient for the CSBs. We are held to, and audited by, the regulations. A supplementary document that is not regulation will not work if we are out of compliance with a staffing or procedural regulation. 

It's essential that some of these adjustments be reflected in the regulations when they are published on December 1. If not, it's likely that critical services will be shut down (e.g., a Residential Crisis Stabilization Unit) and that will definitely not serve the community or the state.

CommentID: 116695