Throughout the different chapters there are inconsistencies to how certain qualified provider groups and services are referenced. Please consider using consistent terminology and phrasing throughout. 

In all draft LEA chapters, the Mental/Behavioral Health sections do not provide consistency in terminology and are hard to understand the expectations of the requirements. Chapter 6 specifically is extremely confusing with the layout of expectations/documentation requirements for planned versus unplanned services.

I also have serious concerns about the 30 day signature requirement for Medicaid documentation. There are multiple factors that could impact a provider's ability to enter and sign electronic documentation (typically impact school divisions using documentation vendors) within a 30 day window including but not limited to their caseload sizes, service delivery models of IEP services (no built in time or appropriate settings to enter electronic documentation), retroactive eligibility (school divisions only get quarterly snapshot Medicaid eligibility), etc.  I understand that this is often best practice from a clinical perspective, but I have reservations about it due to the practicality behind school service delivery and documented.