The increasing emphasis on meeting predefined “intensity levels” also shifts attention away from client-centered care. Time spent ensuring each individual is categorized correctly detracts from time that could be spent delivering individualized support and treatment.

The newly proposed documentation requirements — including recording intensity of need, adhering to caseload maximums, and meeting mandated minimum service hours per individual — introduce unrealistic administrative demands that threaten continuity of care and increase the likelihood of unnecessary case manager transitions.

Furthermore, it remains unclear what specific problem DMAS intends to address through these changes. The proposed “intensity of need” classifications (high, medium, or low), which must be reviewed and documented every 90 days, do not reflect the fluid and dynamic nature of the population we serve. Many individuals’ needs fluctuate frequently, making such rigid classifications clinically impractical.

Ultimately, the proposed system creates a complex and cumbersome classification structure that is difficult to operationalize within existing electronic health record systems and risks diverting valuable time and resources away from direct care.