As a Licensed Clinician and Clinical Supervisor in the state of Virginia, I am extremely concerned about the new crisis protocols. Private providers are tasked with providing 23hr crisis services to individuals in the community who are often dual diagnosed with mental health and substance abuse needs and there is minimal safety protocol. I am hearing that these facilities have one LPN (under supervision of RN, unsure of when they supervise how is this tracked) that check vitals on intake prior to a clinical assessment. According to residents that I train and supervise there is no required UDS, a psychiatrist or NP is not available at most facilities.  I asked about training for Narcan for the possibility of heroin overdose, there is not policy about weapons or drugs in the facility.  There isn't even a policy on drug interaction or food allergies protocols. This service is intended to be an intervention prior to the hospital but is not required to do any of the required medical and or safety protocols hospitals have to report as part of their intake assessment.

There are obvious safety concerns not to mention the ethical concerns of assessment individual prior to determining if there is a significant level of intoxication.

I know that this is a critical resource, and I am concerned about the actual benefit to the patients. When a company can essential add on a higher level of care for individual who are already at a higher level of acuity and are able to bill and be reimbursed for 1 hr. or 23 hours, it opens up several issues.  Individuals are quickly assessment and funneled to community crisis in the same business.  We know many of this companies are using hotels to manage housing needs in community programs and housing is a huge impacting issue.

I would suggest a minimum observational time and initial urine screens in 23 hr crisis. The individuals that access crisis services need staff and clinicians trained in safety protocol, medication management, and clinical training for both mental health and substance use disorder.

There needs to be a restructuring of these programs to better serve the people who need them most.