Thank-you for the opportunity to provide comments.

105-520 - Risk Management - The wording in the regulations “incorporate uniform risk triggers and thresholds as defined by the department” is undefined and should either be removed from regulations or defined in regulations  as this leaves it open for interpretation.

105-580 - Service description requirements - C.2. A description of care, treatment, training skills acquisition, or other supports provided. The term “acquisition” is awkward language.

105-650 - Assessment Policy - F. A. comprehensive assessment shall update and finalize the initial assessment. There are questions regarding this requirement and Same Day Access Services.  We have received feedback that two separate assessments are needed; the initial assessment and the comprehensive assessment, on our SDA form we now have to identify which part is the initial and which part is the comprehensive. This needs clarification as it relates to the State’s SDA initiatives.

105-665 - ISP requirements - A.11. Does this only apply to DD Waiver CD services? The ISP shall be distributed to the individual and others authorized to receive it. What if the individual does not want a copy of the ISP?

105-675 - Reassessments and ISP reviews -

A.  Update the ISP whenever there is “any” kind of change? Is the review not sufficient? Definitely, if something new that needs addressing but does this include every improvement outside of the review period?

D.2. Currently this is documented that the individual has met an objective, what additional documentation is being proposed?

D.3. Requiring a team meeting when individuals do not meet specific objectives is difficult.  Individuals may have many objectives to reach a goal and have several goals. Requiring a team meeting each time a specific objective is not meet will feel punitive to an individual who is trying to reach their goals and may dramatically impact direct service time. How is the team defined? So if an objective on the ISP that the client will visit the primary care office in the next quarter, and the client cancels the visit, do we bring the whole team together to discuss why the client cancelled the appointment?  Requiring the team to meet should be removed.

105-691 - Transition of individuals among services - Further clarification is needed to define transition/transfer. If an individual moves from one case management team to another case management team is this a transfer needing a transfer summary?

105-1245 -   Case Management direct assessments - This is too ambiguous—who determines how often the individual’s needs dictate face-to-face contact?  We have some occasions, when we are seeing case management clients multiple times in the same week for MH case management—would we have to do (I,ii,iii,iv)at each face-to-face visit?