Section 2, Service Definition/Critical Features
- I am concerned that Supported Employment and Education Specialist is not listed as a critical feature of CSC as CSC is an evidence-based model that includes an SEES, and would recommend reconsideration of this piece of CSC.

Section 3, Required Service Components

- 3.5- Concern about the group cap of 10 individuals for Family group- I feel this cap is too small as it could easily be met with just 2-3 clients + their families. I would suggest increasing the cap or introducing a ratio, such as 10 individuals to 1 staff member, with the flexibility of increasing staff and participants.

- 3.7- again, I am concerned about the downplay of the SEES component of CSC and the language in this section that states it is not a Medicaid-covered service. If CSC is becoming a Medicaid-covered service and SEES is a component of CSC, I would request reconsideration about its inclusion in these regs.

- 3.9- As with CPST, I remain concerned about the expectation for CSC to operate as a crisis service without sufficient funding or training and would recommend more flexible language or updating requirements for 24/7/365 in-person crisis support as crisis support services are a separate service that already exist.

Section 4, Provider Qualification Requirements

- 4.1- SEES staff role is listed here which is contradictory to the language in 3.7 where it is stated that supported education and employment are not allowable. Updated language and/or clarification are needed.

- 4.1- further clarification is requested regarding what the DBHDS criteria are for a co-occurring disorder specialist.

- 4.2- I echo others' concern for the team caseload cap is 30 and would suggest reconsideration to an increase in this cap. Additionally, further clarification is needed. Will the cap be 30 regardless of clients' Medicaid status? Remember that the majority of CSC recipients do not have Medicaid.

- 4.4 Further clarification is requested regarding the clinical consultation requirements for the psychiatric provider. If the prescriber is the only prescriber in the agency, from where should they receive their clinical consultation? Who is considered qualified to provide the clinical consultation?

Section 7, Service Authorization

- Clarification is requested regarding language surrounding group sizes. In this section, the language uses ratios- 1 staff for every 6 youth, and 1 staff for 10 adults. The language is not the same in other parts of the regs where it just said groups are limited to 6 or 10 people. 

- Updated language is needed to address caps for groups of youth and adults mixed.

- Level of Need- There needs to be flexibility to "toggle" between a monthly and an encounter rate both with billing and with the authorizations. As a current provider of CSC, I want to explain how significant the inconsistency is with client engagement to this service. Due to their age, significant symptoms, and where they're at in their recovery, they are unlike any other population that we serve. DMAS and DBHDS need to be aware of their own unique engagement style and needs. It is incredibly difficult for most clients to make all or even most of their scheduled appointments due to these barriers. I am certain that no matter how hard we try and how much advanced planning we do for services to meet the monthly encounter frequency, from month to month there will be inconsistencies where clients only meet 6 times, or 5 times. If that occurs, and we have an auth in place for a monthly rate with no flexibility to bill the encounter rate, that means we will get $0 reimbursement for that month for that client, even though we will have seen them 5 or 6 times. For the authorization, please clarify in the regs if one authorization will cover both the monthly and the encounter billing codes, or if there will be 2 separate auths. I would be happy to be contacted to provide more information about encounter and engagement rates and/or data of our current clients' engagement rates.

Section 8, Additional Documentation...

- Please clarify how #4 will be operationalized. What counts as a "progress note in the individual's chart" as sufficient for the LMHP to have reviewed the nonlicensed staff's documentation? Would that just be a monthly attestation document where the LMHP attests that they have reviewed the staff's documentation? Or do you mean an actual progress note by the LMHP documenting an encounter with the client?