I have several concerns with the following Case Management Agency Requirement: "Guarantee that individuals have access to emergency assistance either directly or on-call 24 hours per day, seven days per week and holidays. This may be done via telephone and face-to-face contact and/or coordination with other providers and DBHDS administered crisis services."

Could you please clarify what constitutes emergency assistance? Non-profit organizations such as Brain Injury Services (and others who provide case management for brain injury) do not provide emergency assistance, as we are not a medical nor emergency mental health provider. Because we are not an emergency/crisis resource, we educate and prepare clients about when and how to use 911 and 988 as needed. To my knowledge, there is no published empirical evidence that non-medical brain injury case management services would benefit from 24/7 availability. 

Instead, this would be a disservice to not only the service providers, but also to the clients. As Lisa McCarthy stated, requiring 24/7 availability would lead to significant financial burdens for agencies and lead to even higher turnover rates in a profession already struggling with widespread burnout. Without significant funding increases from the state, agencies also could not afford to compensate employees who are required to be available for more than their 40 hour work week, or to hire staff for a 24/7 call center. This would certainly lead to a greater number of clients being underserved. At the end of the day, the clients are the ones who would be harmed by this.

Thank you for considering our feedback.