RCPA, in partnership with its members, has submitted public comments in response to the Office of Mental Health and Substance Abuse Services’ (OMHSAS) proposed Licensure of Crisis Intervention Services regulations. RCPA thanks OMHSAS for their effort in creating licensing standards that align with national best practice standards for the Commonwealth’s crisis intervention system and their receptivity to further recommendations from current crisis providers.
The proposed regulations have been reviewed by members of RCPA’s 988/Crisis Work Group, who are some of the most experienced and knowledgeable leaders in Pennsylvania’s Crisis System. With their expertise, RCPA developed comments and recommendations to guide the State towards meaningful regulations for Crisis Intervention Licensure.
The largest areas of concern in the proposed regulations are in regard to the staffing requirements and fiscal impacts, which led to the following recommendations:
- Flexibility in the staffing requirements to account for the national behavioral health workforce shortage.
- A transparent cost analysis of the true cost of implementing the regulations to ensure that the regulations do not become an unfunded mandate.
- Increased clarity on the role of community outpatient clinics that are not connected to larger hospital systems.
- The assembly of a stakeholder work group, similar to the forums that OMHSAS convened for their PRTF regulations, to ensure that provider and other stakeholder concerns are addressed before promulgation of the regulations.
Read RCPA’s full public comments here. Contact Emma Sharp with any questions.
