Our agency has concerns about moving forward with an overhaul of the regulations, particularly given the many changes underway at the Department of Medical Assistance (DMAS). The DMAS redesign changes are significant, and moving forward simultaneously could create confusion and inconsistency for providers. This would place an added burden on agencies and staff who are already working hard to learn and adapt to the coming DMAS changes. We believe it would be most effective to allow DMAS redesign to be finalized before undertaking additional regulatory overhauls.

If DBHDS does decide to continue with revisions at this time, we respectfully request that the new regulations be aligned with DMAS and the MCO’s to ensure consistency across agencies.