The first and highest concern is the requirement to meet clients in the community at least once every 90 days "outside of a CSB". There is no language that takes into consideration inclusion of the client's choice. This runs directly opposed to the language about the ISP being "person centered". It also does not consider recovery model planning (least restrictive) and forces a meeting in a location where the client may not want to meet and/or is not appropriate for the persons level of functioning. The location of services should always be a clinical assessment and agreement between the clinician and the client. Does the client declining meeting in the community force them to be ineligible for and/or discharged from the service? 

The second concern is the caseloads and hours. As it is written, it seems that there will need to be a tremendous amount of calculations being done by managers and/or QI departments to calculate caseloads and average hours and have that contingent on assessed CM intensity. This would be a constantly moving target given client's level of need and intensity can change frequently. This introduces unnecessary and unhelpful distraction for providers and could cause harmful transfers which disrupts the provider/client relationship.