As St. Elizabeths Hospital gears up for its first comprehensive review by outsiders in three years, the District faces an uphill battle in winning accreditation for the hospital and the rest of the city's new mental health care system, city and other health officials say.

Dr. Robert A. Washington, the District's mental health commissioner, conceded in an interview yesterday that he "absolutely" expects difficulties in the system winning accreditation from the Chicago-based Joint Commission on Accreditation of Hospitals, the principal accrediting body for the country's hospitals.

"This is a brand new system that has not had the opportunity in an unpressed way to prepare for accreditation," Washington said, noting that the review process comes only a few months after the federal government formally transferred control of the psychiatric hospital to the D.C. government.

One of the system's main problems is a shortage of trained staff -- a critical issue in accreditation -- as well as bringing the community health centers in the District up to the joint commission's standards, officials with the city mental health commission said.

While Washington expressed confidence that the system will overcome these difficulties and win accreditation, other doctors and observers of St. Elizabeths were more pessimistic. "As it stands now, there is no chance" of accreditation, said one informed physician on the grounds of St. Elizabeths.

The issue of accreditation is critical for the city's new Commission on Mental Health Services, perhaps more for political reasons than health care reasons.

Other public mental health facilities operate without accreditation, but losing that seal of approval, as St. Elizabeths once did in the 1970s, could be a powerful blow to the credibility of the city government and confirm the fears of some doctors at St. Elizabeths that the District cannot run a quality mental health program.

"You do not have to be accredited to be good," Washington said yesterday. "But if we don't seek accreditation, the public will say the District transferred control and lost accreditation.

"It will support the stereotype of incompetence, which is both suggested for reasons of race and governance," Washington added.

The transition plan for St. Elizabeths calls for the gradual release of many of the hospital's patients into group homes and other community facilities as direct federal subsidies are phased out. The ultimate goal is to have a community-oriented system rather than a hospital-oriented system, but in the meantime, the question of how to define the system has bred some confusion with the accrediting agency.

Inspectors from the joint commission are expected to make a visit to St. Elizabeths in the late spring or summer, but Washington has already asked it to evaluate St. Elizabeths as a "community mental health system" -- not a hospital, as it was previously graded.

Washington said the main reason for this request was that it more accurately reflects the commission's services throughout the hospital grounds and in the city. While there are nearly 1,500 adult patients who remain at St. Elizabeths, Washington estimated that only about 200 require acute psychiatric care, while the rest receive some kind of chronic or even custodial care.

"We are a community mental health care system," Washington said. "It just so happens that a lot of our resources are {tied} up in St. Elizabeths Hospital."

However, some observers are skeptical of Washington's intentions and speculate that seeking qualification as a community mental health center is an effort to obtain a review under less stringent standards.

"They realize that they do not measure up to the hospital standards," said Terry Lynch, executive director of the Downtown Cluster of Congregations, a group that provides shelter and other services for the homeless. "The city has very little commitment to having a quality hospital for the mentally ill . . . . The whole accreditation thing is evidence."

Sources indicated that the joint commission has balked at Washington's proposals, but the mental health commissioner said this is because of a misunderstanding of what goes on at St. Elizabeths. He said the matter could be cleared up at a March 14 meeting with joint commission representatives.

In addition, there are about 700 job vacancies in the District mental health system, or at least 20 percent of the work force. While Washington attributed this in part to delays associated with the transition process, the commission projects that it will continue to face a severe shortage of registered nurses, like many hospitals around the area.