I am writing to provide feedback on the proposed regulations for Crisis Services, specifically addressing several points outlined in the sections of 12VAC35-111. I appreciate the opportunity to contribute to this important discussion and recommend adjustments to ensure these regulations are effective and aligned with best practices.

1. 12VAC35-111-10 - Definitions:

   1. I recommend using “Community Stabilization” instead of “Community Based Crisis Stabilization” to maintain consistency with DMAS language and service definitions.

   2. Adjusting the language from “…experiencing a behavioral loss of control” to “behavioral crisis” aligns closer with a person-centered approach.

2. 12VAC35-111-20- Licenses:

   1. I recommend the following licenses: Crisis Receiving Center, Community-based Stabilization, Mobile Crisis Response (includes REACH MCR which should be licensed under this), Emergency Services, REACH Community Stabilization, REACH Crisis Therapeutic Home, and Crisis Stabilization Unit.

3. 12VAC35 – 111-30 Service Descriptions:

   1. Clarification is needed regarding the requirement of a nursing assessment, as it contradicts the regulation stating that nursing assessments are not required for Crisis Receiving Centers.

   2. The regulation should state that providers shall have a policy to address custody of children accompanying parents but shall not be responsible for the children’s safety on the unit.

4. 12VAC35 – 111 – 40 Staffing:

   1. The requirement in Line B2 may be specific to the VCC platform and is not appropriate for inclusion in licensing regulations.

   2. Providers of mobile crisis response do not “dispatch” calls; the regulation should be revised to read: “If a team response is recommended at dispatch…”

   3. Change the language from QMHP-E to QMHP-T in Line B3 ii - 6.

5. 12VAC35 – 111 – 50 Initial Contacts:

   1. Define “initial contact” in the definitions section for clarity.

   2. Recommend adding clarifying language regarding intent or removing added reporting requirements.

   3. Service linkages or referrals should not be required unless a service is rendered.

6. 12VAC35 – 111 – 80 Safety plan and Crisis ISP requirements:

   1. Omit the underlined portions to reduce administrative burden.

   2. The focus should be on clinical treatment rather than documenting attempts to obtain signatures.

7. 12VAC35 – 111 – 90 Reassessments and Review of Safety Plans and Crisis ISPs:

   1. Clarify which services this regulation applies to; it should not apply to services that are for 72 hours or less.

8. 12VAC35 – 111 – 110 Discharge Planning:

   1. Correct the code reference to 12VAC35-105-693.

   2. The Discharge Planning section needs clarity and consistency regarding required services and steps.

9. 12VAC35 – 111 -120 Written policies and procedures for crisis or emergency response; required elements:

   1. Remove “face sheet” terminology for clarity.

10. 12VAC35 – 111 - 130 Nursing assessment:

    1. Ensure alignment with DMAS regulations and clarify the type of service setting this requirement pertains to.

    2. Nurses should not be responsible for diagnosing underlying conditions.

11. 12VAC35 – 111 – 140 Health Care Policy:

    1. Revise to focus on addressing “acute” medical and dental needs only.

These recommendations aim to improve the clarity, consistency, and effectiveness of the proposed regulations for Crisis Services. These adjustments will better support providers in delivering person-centered, trauma-informed care while reducing administrative burdens.

I look forward to the continued progress and improvement of Crisis Services in our community.