As a private provider, I ask that we consider the environment we create for the individuals receiving services.  We must balance treatment without overburdening the individuals receiving services.  5.5 hours of direct educational services, coupled with formulaic therapeutic processes outlined in the proposed regulations do not ensure improvement or hope.   It binds providers to a rigid system that do not allow for individualized treatment, where the patient is at the center of their treatment plan.  Requirements for three individual therapy sessions per week, regardless of the individualized need, or the status of the individual during that week of services.  Three interventions per day, versus allowing the provider to meet the individuals specific needs as the treatment team deems appropriate.  I do appreciate that the regulations do now allow for the provider to “miss” interventions relative to what is occurring that day for the individual.  However, these arbitrary requirements do not truly speak to the need for individualized programming.  I would recommend that the Behavioral Health Services Administrator be granted the authority to review each Service Authorization Request, and review admission and continued stay based on the programming that is being proposed by the provider.  Allow the provider to justify their clinical decisions, and create the nurturing environment to improve the mental health of the individual.  Active treatment should be the focus of treatment.  To this end, I also recommend that we consider speaking with individuals here in Virginia that receive services.  Seek their feedback regarding their treatment regimen.  How do they feel, relative to the academic and therapeutic structure while in treatment.