I would like to start by stating that after processing these changes, I cannot figure out how this could possibly have a positive impact on the clients it is meant to serve. We work with some of the most vulnerable population, which, by the way has already fallen through the cracks in so many other systems. If these new regulations and billing codes go into effect as planned, all it will do is further inhibit the progress that this population deserves to achieve.
The following are my primary concerns with the proposed changes: