Section 3.2.3: Care coordination is an essential component of effective service delivery and should be clearly integrated into work with all clients. We recommend adding clarification regarding how the client’s MCO will be notified. For example, will this notification be documented through the prior authorization process, or will a separate form or process be required? We are also concerned that this requirement may create an additional administrative burden for providers, particularly if the associated time is not billable. Additionally, item #4 references the inclusion of a plan within the ISP to transition the client to an evidence-based practice when clinically appropriate. We recommend further clarification regarding how “clinically appropriate” will be defined and measured, particularly in situations where the provider and MCO may have differing clinical perspectives.

Section 4.2: We support Clinical Directors assisting with cases when necessary and clinically appropriate. However, we recommend additional clarification regarding the use of the word “shall.” Specifically, is the expectation that the Clinical Director be present for sessions when they are not serving in the role of CPST Supervisor? Clarifying this expectation would help agencies better understand staffing requirements and operational responsibilities.

Section 5.1: The ability to share assessments can be beneficial for clients, providers, and care coordination partners. We recommend additional clarification regarding how these assessments may be accessed efficiently and consistently. Because releases of information would need to be obtained and submitted, this process may create a potential bottleneck for both providers and clients seeking timely access to services.

Section 5.2.1: Subsection F(ii) appears to create duplicative work for the agency responsible for developing the ISP. We recommend reviewing this requirement to determine whether it can be streamlined or clarified to avoid unnecessary administrative duplication.

Section 5.2.1(I): We request clarification regarding whether the Clinical Director must also sign off on the ISP when the CPST Supervisor is already an LMHP-type provider. We recommend that an additional Clinical Director signature not be required in these circumstances, as this would add another layer of administrative burden without clear clinical benefit.

Section 10.8: We request clarification regarding what services or supports should be offered to a client when services must be discontinued under this provision. Abruptly ending services after a therapeutic relationship has begun may unintentionally harm clients, particularly those who may already have difficulty trusting providers, opening up, and sharing their experiences. Clear transition expectations would help protect continuity of care and support client stability.

We also recognize that parent or caregiver involvement can improve overall outcomes. Additional clarification would be helpful regarding how providers should proceed when a parent or caregiver refuses to participate at the required level, but the client remains engaged in and benefits from the service.

Section 12.1.3: We request clarification regarding whether LMHP-type providers should be included in this section.

Section 12.1.3(5): We recommend clarification regarding how the required hours will be tracked and who will be responsible for tracking them. Clear guidance would help agencies ensure compliance and consistency across providers.

Attachment 1.1: During one of the MAP training sessions, guidance was provided by a state representative indicating that if a provider completed MAP training, they could provide CPST adult/community services without completing other trainings, such as TCBT. We recommend clarification regarding whether this guidance remains accurate under the proposed changes.

While we support continuing education and the use of evidence-based practices, access to some required training platforms may require providers or agencies to purchase access or pay for trainings. This could create additional financial burden for agencies. We recommend clarification regarding whether free or reduced-cost access to required training courses will continue to be available. Additionally, if providers are permitted to utilize MAP dashboards as ISPs, further guidance is needed regarding how these documents could be integrated into agency EHR systems without creating compliance concerns or having to maintain documentation outside of EHRs.

We also recommend reconsideration of the signature requirements for documentation. Specifically, if the Clinical Supervisor is an LMHP-type provider and is reviewing documentation completed by other LMHP-type providers and QMHPs, clarification is needed regarding whether an additional LMHP signature is required on those documents.

Finally, when an agency is required to submit corrective action plans to MCOs, we recommend that clear standards be provided regarding the circumstances under which an MCO may seek to discontinue services with that agency. Transparent criteria would support fairness, consistency, and improved provider accountability.