According to the draft, all agencies must be accredited to provide any level of service under this new model. DBHDS does not require accreditation in order to be licensed for the service, but this implements the requirement for accreditation under DMAS so that you can be paid. For small agencies, this poses an extreme hardship as accreditation cost upwards of $10,000. That is an astronomical cost to absorb for a small agency especially with low reimbursement rates. If an agency is licensed by DBHDS and not required to be accredited, why would there be a need to be accredited for all providers. Requiring accreditation for those agencies that are not licensed by DBHDS and provide services such as ICC, FFT, MST, etc. that are not DBHDS services but fall under this draft would help hold those to the applicable standards, but it should not be required across the board. Accreditation requirements are time consuming and adding this requirement to the standards that have to be upheld by DBHDS licensing would add redundant work to agencies.