Overall, there has not been a clear definition of what problem DMAS is trying to solve with the proposed changes.  While there have been reference to concerns about case managers billing too many individuals leading to the levels of administrative oversight included in the draft, no data that demonstrates the frequency or extent that this has occurred has been provided (even when requested).   

The proposed changes to Mental Health Case Management (MHCM) services at RACSB will significantly impact both adult and child/adolescent populations, including the 873 individuals served last year. Key concerns include increased face-to-face requirements from once to twice every 90 days, with one visit required in the community, adding travel, coordination, and unfunded administrative burden. Additional home visit and service monitoring requirements, new documentation for medical necessity—especially for children under five or those without prior diagnoses—and continued stay criteria could limit access to essential services for high-need populations. New staff caseload requirements, including documentation of intensity of need, caseload maximums, and mandated minimum service hours per individual, impose unrealistic administrative demands, threaten continuity of care, and may lead to unnecessary transitions between case managers. To mitigate these challenges, RACSB recommends a clear caseload maximum of 60 per case manager per month, allowing flexibility while maintaining high-quality, continuous services.