Thank you for the opportunity to provide feedback on the proposed CANS Lifetime. We feel that several provisions raise some operational, clinical, and administrative concerns for Community Services Boards (CSBs) and other providers.
Navigating the Canvas system and Okta presents significant challenges for staff. Users are automatically locked out if they do not access the system within 30 days, and staff frequently experience additional access and authentication issues. These barriers have the potential to delay completion of required assessments and create unnecessary administrative burden.
The draft also states that supervisors who co-sign CANS assessments must maintain CANS certification. This creates an ongoing requirement for supervisory staff and may present challenges. Obtaining and maintaining certification is not a simple process, and many staff require multiple attempts to pass the certification examination. Requiring certification for both assessors and supervising staff increases training demands.
The requirement to obtain completed CANS from another provider or the MCO may also create delays in service initiation. Coordinating receipt of assessments from external entities will add administrative burden and slow access to needed services.
The draft references required quarterly updates but do not clearly define the scope of these updates and without guidance, providers will implement requirements inconsistently. Additional clarification is needed regarding specific information that must be reviewed or updated, if updates require a formal reassessment of CANS domains, documentation standards that apply and expected time and effort.
The definition of "qualifying events" appears broad and could result in a significant increase in reassessments. For example, trauma disclosure is identified as a qualifying event requiring reassessment. Given the varying definitions and interpretations of trauma across providers and agencies, determining when a disclosure meets the threshold for reassessment may be challenging and could lead to inconsistent implementation and a substantial increase in the number of CANS assessments completed.
The proposed assessment schedule establishes recurring updates every six months for adults, annual comprehensive reassessments, and additional reassessments triggered by qualifying events. While reassessment is important when circumstances change, these requirements create a substantial ongoing workload. Completing a meaningful assessment involves far more than entering ratings into a standardized instrument. It may require clinical interviews, review of medical and behavioral health records, consultation with family members or other providers when appropriate, evaluation of functioning across multiple life domains, documentation of supporting evidence, and integration of findings into an individualized service plan. For CSBs, these responsibilities compete directly with clinician time available for treatment, rehabilitation, crisis intervention, care coordination, and other community-based services.
There are specific concerns regarding Section 5.1.4, which establishes mandatory event-based reassessment requirements following a broad range of clinical, personal, and service-related events. While significant changes in an individual's circumstances may warrant reassessment, the policy requires comprehensive reassessments within specified timeframes for events that vary considerably in their clinical significance and implications for treatment The proposed triggers include psychiatric hospitalization or crisis stabilization discharge, significant clinical improvement or deterioration, new trauma disclosures, changes in household composition, transitions into or out of the justice system, and gaps in services exceeding 90 days. Most of these events require reassessment within 30 days.
For CSBs, these requirements create substantial operational challenges. Such events frequently occur without advance notice and may affect multiple individuals on a provider's caseload within a short period. Completing a comprehensive reassessment requires clinician time, record review, interviews, collateral contacts, clinical formulation, and detailed documentation. These responsibilities must be met while CSB staff continue to provide treatment, crisis intervention, care coordination, and other essential community-based services.
The policy does not distinguish between an event that requires an immediate clinical response and an event that necessarily requires a complete reassessment of every CANS domain. For example, a new trauma disclosure may warrant sensitive therapeutic support and a targeted safety assessment without necessarily changing the individual's overall service needs. A change in household composition may or may not have a meaningful effect on clinical functioning. Similarly, improvement in symptoms may reflect successful treatment rather than a need to initiate another comprehensive assessment.
There is concern about the interaction between these mandatory deadlines and the reimbursement provisions. Section 7.2.1 requires event-based reassessments to be billed under H0031 with the U1 modifier and requires service authorization before billing. This creates a potential conflict between the obligation to complete a reassessment within the specified timeframe and the uncertainty of obtaining timely authorization and reimbursement.
The draft references interim tools for documenting assessments and calculating Levels of Need while longer-term electronic infrastructure is developed. It also indicates that service-planning algorithms and additional requirements will be implemented in future phases. This phased approach raises concerns regarding readiness, operational consistency, staff training requirements, and the ability of providers to implement requirements effectively while key infrastructure and processes remain under development.