IRRC Releases Licensure of Crisis Intervention Services Comments

The Independent Regulatory Review Commission (IRRC) has published their comments on the proposed Licensure of Crisis Intervention Services regulations, summarizing the comments submitted by the stakeholder community during the public comment period.

As part of the IRRC’s regulatory process, OMHSAS will have to address and clarify any questions that have been submitted.

Similar to RCPA’s public comments, the IRRC response highlights concerns regarding the proposed rulemaking in the following areas:

• Potential issues with “one-size-fits-all” approach to crisis intervention.
• Lack of availability of qualified staff and how to pay for them.
• Elimination of an “in-between” level of care by imposing hospital-like standards that do not align with current outpatient structures.
• Possibility of inadequate government funding to cover providers’ implementation costs.
• Lack of inclusion and integration with law enforcement, first responders, 911 operators, and 988 lifeline centers.

In support of RCPA’s recommendation, the IRRC comments also urge the Department to reconvene the stakeholder work group that had been assembled in 2021, especially given the drastic shift in the mental health landscape that has occurred since the group last met.

Please contact Emma Sharp with any questions.