The draft introduces substantial new documentation requirements that will require significant revisions to agency documentation systems, policies, electronic health records, and staff workflows.

Examples include:

• Documentation of each evidence-based practice protocol within the Individual Service Plan (ISP).
• Quarterly updates for each protocol.
• Expanded crisis planning documentation.
• Documentation supporting referrals—or reasons for not referring—to standalone EBPs.
• Required notification to Managed Care Organizations (MCOs) each time an individual accesses crisis services.
• Reporting DBHDS Corrective Action Plans (CAPs) to MCOs.
• Submission and ongoing maintenance of provider qualifications through CEP-VA.
• Maintaining detailed caseload tracking logs and six-month average caseload calculations.

Collectively, these requirements significantly increase administrative workload without clear evidence that they will improve clinical outcomes or patient care.