I work in a Outpatient Program with a CSB, and I have some concerns about the proposed MHCM Level of Care Guidelines and the new Intensity of Need model. I understand the goal is to improve service quality and accountability, but I’m worried that the way these changes are structured could actually make it harder for staff to do their jobs and for clients to get the care they need.

Right now, case managers are able to adjust the level of service based on each client’s needs. If someone is going through a crisis, like homelessness, health issues, or a mental health emergency, we can increase contact, coordinate with other providers, and respond in the moment. The new model seems to focus more on paperwork and following strict guidelines than on actually helping clients when they need it most.

The increased face-to-face requirements—doubling the number of contacts every 90 days and requiring at least one to be in the community—will take a lot of extra time and travel. For clients who live far away or in rural areas, this will make it harder to spend time on coordination, crisis response, and other important work. Raising the minimum for everyone may also limit our ability to give extra attention to clients who really need it.

The proposed caseload rules also worry me. Categorizing, justifying, and calculating caseload metrics will take time away from direct client care. Mixed caseloads make it even harder—clients might have to switch case managers just to meet ratio rules. That could disrupt trust and rapport, which take a long time to build.

Finally, the “intensity of need” classifications (high, medium, low) that have to be reviewed every 90 days don’t reflect how quickly a client’s needs can change. People’s situations can shift week to week, or even day to day. Rigidly sticking to these categories feels unrealistic and could create extra paperwork without actually improving care.

Overall, I’m concerned that these changes would pull staff away from direct support and make it harder to provide the kind of flexible, responsive care our clients need.