|Received Date||Received From (Name or Affiliation)||Comment|
|06/18/2021||Amy Westling - ARCA||File Attachment (PDF)|
|06/14/2021||Bruce A Wexler||
Page 18, 59010.1: It is well recognized that prone and/or supine holds represent potential high risk to consumers, and should only be used in significant emergency situations. The proposed regulations indicate these two specific holds are "prohibited". Given the anticipated needs and challenges of adolescent consumers that are expected in our Crisis Homes, the option to utilize a prone hold is seen as an essential tool under very limited conditions. It is suggested that the wording be revised to indicate that, "Prone and/or supine holds shall only be used in circumstances when imminent risk is present and the use of alternative de-escalation techniques have been exhausted".
Last modified: June 22, 2021