1. Pg. 31. At the start of services, a [LMHP-type], must conduct an assessment to determine the individual’s appropriateness for the service.  

Requesting clarification on “at the start of services” time frame. Recommend revising to  “within 24 hours of admission to services.” 

2. Pg. 32- A psychiatric evaluation by a psychiatrist, nurse practitioner, or physician assistant must be available at the time of admission into the service.  

Requesting clarification on “at the time of admission” time frame,  and recommend revising to read “within 24 hours of admission” in order to complete admission intake to services in a manner that is person-centered and trauma-informed for the individual receiving services, to be cognizant of prescriber availability, and to align with established ARTS requirements.  

3. pg. 35, A licensed psychiatrist or psychiatric nurse practitioner must be available to the program 24/7 either in-person or via telemedicine to provide assessment, treatment recommendations, and consultation. 

Recommend revising to include having access to a licensed psychiatrist or psychiatric nurse practitioner via telephone 24/7, not exclusively in-person or telemedicine.  

4. Pg. 35 Nursing services shall be provided by a RN or a LPN working directly under an RN who is present on the unit. 

Taking nursing workforce challenges into consideration, would recommend LPNs work under indirect supervision of an RN to include 24/7 access to the RN supervisor, on-going in person supervision, and on-going review of documentation.  

5. Pg. 36 Medical Necessity Criteria- The RCSU Service Definition and Critical Features & Service Components sections of the manual states that RCSUs also serve as a stepdown option from psychiatric inpatient hospitalization and function to stabilize and reintegrate individuals who meet medical necessity criteria back in to their communities. 

 If an individual meets RCSU MNC outlined in this manual, they would not meet discharge criteria from a hospital to step down. Recommend revising MNC to be more inclusive of psychiatric step-downs.