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Dear Deputy Director Posner: 

On behalf of more than 400 hospitals and health systems, including 32 free-standing acute psychiatric hospitals and 72 general acute care hospitals with psychiatric units, the California Hospital Association (CHA) offers the following recommendations on acute psychiatric hospital staffing regulations. 

These recommendations follow the California Department of Public Health (CDPH) announcement on April 29 that it would be developing new regulations, and all recommendations support one critical fact: staffing mandates for psychiatric hospitals must reflect the nationally recognized, multi-disciplinary team approach to providing high-quality care and safety for patients experiencing a mental health crisis. 

CHA is grateful for the opportunity to provide recommendations specifically in response to the discussion questions that CDPH provided as an attachment to All Facilities Letter 25-16. Attached is also a sample acute psychiatric hospital daily schedule, which CDPH requested for informational purposes. 

As CDPH commences work to develop minimum staffing regulations for acute psychiatric hospitals, the department should consider that patients who are experiencing mental health crises have very different clinical and environmental needs than those who need care in general acute care hospitals.  

California’s staffing requirements for medical-surgical hospitals are largely focused on nursing personnel because patients hospitalized for physical health conditions receive critical treatment performed most appropriately and typically by nurses (e.g., wound care, dressing changes, IV insertion, diagnostic tests, assistance with mobility, etc.). Acute psychiatric hospitals, however, focus primarily on restoring the emotional well-being of patients whose mental health symptoms put them at imminent risk of harming themselves or others. This treatment is typically — and appropriately — performed by an interdisciplinary team of health professionals.  ​​

Unfortunately, California lacks sufficient access to this life-saving model of psychiatric inpatient care. Well-established benchmarks suggest that at least 50 staffed psychiatric beds are needed per 100,000 people.[​1]​ ​While countries in Europe average 75 beds per 100,000 people,[2]​ California only has a mere 25 — fewer than even Mississippi or Montana.