Recommend DMAS and DBHDS work together to align paperwork reduction efforts into draft regulations and manuals.

Gaps in service: currently require new Comprehensive Needs Assessment if no services in 31 days. Recommend changing this to need Comprehensive Needs Assessment Update. Many states use abbreviated Comprehensive Needs Assessment Update Form for people re-entering services any time less than 1 year.  Historical items on the assessment should not change.

Comprehensive Needs Assessment: If ISPs are reviewed every 90 days, quarterly reviews are required, and a new ISP is due every year, recommend discontinuing needing a new annual Comprehensive Needs Assessment due to duplication.

Additional Requirements for MHSS, PSR and ICT (is this ACT?): Recommend striking this section requiring 6 month reviews. Quarterly Reviews for ISPs are already required and the six month review is redundant. Service Authorizations also cover this aspect.

Additional Requirements for Day Treatment/Partial Hospitalization MH-PHP and MH-IOP: Recommend striking this section requiring evaluation and documentation of continued medical necessity. Quarterly Reviews for ISPs are already required at the 90 day mark. Service authorizations will likely already cover theses aspects.