MH requirements are greatly above that for ARTS programs, allow little flexibility, and concerned will deter many from implementing these much needed services. Despite more requirements, rate is considerably less than ARTS. Suggest re-aligning closer to ARTS format. Recommend not passing this appendix without more review and input. What many understood as intended to be an alignment with ARTS IOP and PH, seems to be more of a creation of stand-alone program/clinic, versus a new ability to offer a similar group service structure for MH. With the numerous competing demands, changes and current requests, suspect many agencies have not had time to review thoroughly and give input.
A few key point examples from the MH IOP draft regs:
Reminder of rate differences:
ARTS IOP rate: $250 group
MH IOP rate: $141.50 per diem
ARTS PH: $500 group
MH PH: $120.58 ($220 if in a hospital) per diem