We strongly oppose the change as written.  DBHDS indicates the proposed changes are to align the ISP Quarterly Review Dates with DMAS regulations.  While the attempt to align requirements is appreciated, this proposed change is not in line with the established processes and DMAS requirements for Developmental Support Coordination (Case Management) and Mental Health Case Management.  The current requirement for completing the Case Management/Support Coordination Quarterly is 30 days from the date the Quarterly Review Period ended.  This timing in critical for Support Coordinators/Case Managers to complete the requirements of their job and ensure ability to review services provided to individuals.  Further, this is critically important for Support Coordinators to meet the expectations for oversight of services as indicated in the DOJ settlement agreement.  Other providers must submit their quarterlies to the Support Coordinator so the Support Coordinator can review how all services are going for the individual.  Further, the Support Coordination/Case management review of providers’ Quarterly ISP reviews helps to identify risks so they can be addressed. 

It is suggested the regulation be changed to be effective for all services except Case Management Services.  Then adding the following requirement for Case Management:  Case Management services must complete the Review documentation and add to the individual’s record no later than 30 calendar days from the date the review period ended.