The Region 5 Crisis Taskforce believes that lumping Crisis Stabilization, Mobile Crisis Response, REACH, and Emergency Services into a single license there is a general lack of clarity and the context in which each service is provided is lost.  Each service has a defined purpose across the crisis continuum and in some cases such as pre-admission screening, it creates blurred boundaries of public and private responsibilities outlined in Virginia Code and does not properly take into account the unique training required by Pre-Admission Screeners.  We recommend separate and distinct licenses for each of these services to clarify staff training requirements, team compositions, and to maintain fidelity to the services outlined.

Specific Comments:

1. Pg. 3 Paragraph 2:  Is the comprehensive assessment listed here the DBHDS Approved Crisis Assessment from the DMAS regulations?  Clarity is needed here.
2. Pg. 3 Paragraph 3:  Line 15, recommend changing “or the individual’s support system” to “and as appropriate the individual’s support system.”
3. Pg. 3 Paragraph 3:  Line 15-16, recommend striking “between an initial mobile crisis response and entry into an established follow-up service at the appropriate level of care.”
4. Pg. 9 Paragraph 1:  Recommend the following licenses:
   1. Crisis Receiving Center
   2. Community-based Stabilization
   3. Mobile Crisis Response
   4. Emergency Services
   5. REACH Mobile Response and Stabilization
   6. REACH Crisis Therapeutic Home
   7. Crisis Stabilization Unit
5. Pg. 9 Paragraph 2: Line 7, a nursing assessment is required, however; on page 19 under “Nursing Assessment” the regulation states that nursing assessments are not required for Crisis Receiving Centers.
6. Pg. 9 Paragraph 2:  Lines 11-12, a CRC shall have policy to address custody of children accompanying a parent for treatment, but shall not be responsible for maintaining those children’s safety on the unit.  Additionally, there should be a requirement for addressing children being assessed at the CRC and accompanied by their parents.
7. Pg 9 Paragraph 3:  See comments related to confusion of lumping multiple services under one license above.
8. Pg. 9 Paragraph 3:  Pre-admission screening and Emergency Services should be properly defined under a unique license to reflect the codified responsibilities and training unique to this service.
9. Pg. 10 Paragraph 1:  Lines 9-10, See Comment 6 above.
10. Pg. 10 Paragraph 2:  Lines 7-8, Individuals utilizing substances are not prohibited from enrollment in REACH services. 
11. Pg. 10 Paragraph 4:  Note staffing is complicated in this section due to the bundling of multiple services under a singular license, See Comment 4 above.
12. Pg. 10 Paragraph 4:  Item 2, we believe this is a requirement of the VCC platform and is inappropriate to include in a licensing regulation.
13. Pg. 10 Paragraph 4:  Item ii., Providers of MCR do not dispatch, this is a function of the regional hub.  Recommend rephrasing to read:  If a team response is recommended by the regional hub at dispatch…
14. Pg. 11 Item C. 5.:  Recommend separate licenses for REACH CTH and that MCO’s accept this definition for billing purposes to ensure alignment with DOJ requirements.
15. Pg. 11 Initial Contacts – We recommend that an initial contact be defined in the definitions section. 
16. Pg. 13 Crisis Assessment:  We recommend that the form dictate the information to be collected.  DBHDS has published a Crisis Assessment form and all required information should be indicated within that form.  The elements listed on this page are more closely aligned with a CNA than the crisis assessment.
17. Pg. 14 Item H:  Retention of records is covered in Code, there is not reason to add it here.
18. Pg. 14 Item B:  Recommend that a singular CEPP be required for REACH services, provisional and final CEPPs are not consistent with best practice.
19. Pg. 18 Discharge Planning Item B:  Why would a CRC not be required to provide discharge planning instructions and coordinate care with the rest of the service system on behalf of the individual being served?
20. Pg. 19 Nursing Assessment:  See Comment 5