Thank you for the opportunity to provide feedback on the restructuring of the DBHDS licensing regulations into a general chapter with multiple service-specific chapters. I would like to submit the following concerns:

Fragmentation: splitting licensing rules into six categories may create confusion for providers operating across multiple service types. Staff will need to cross-reference multiple sources, increasing the risk of inconsistency and compliance errors.

Regulatory Overload: CSBs are already implementing major initiatives, including Marcus Alert, crisis service transformation, new performance contract requirements, and overwhelming providers and diverting resources away from care.

Transparency: The absence of a public hearing limits meaningful stakeholder engagement on changes of this scale.

Recommendations

Phase-In Changes: address urgent gaps first, delaying full restructuring until the system stabilizes.

Provide a Central Reference: if separate chapters are adopted, create a consolidated tool to show how requirements interact.

Hold a Public Hearing: allow providers, families, and advocates to give direct input.

Impact Analysis: Assess the administrative and financial burdens on CSBs and other community providers

While clarity is important, moving forward now with a broad restructuring risks duplications and instability, particularly with the massive DMAS changes and the need for those changes to properly align with DBHDS regulations, as they often do not. A phased, coordinated approach would better serve providers, individuals, and the Commonwealth.