Regarding the level of intensity tiers, caseload requirements and contact minimums:

Rockbridge Area Community Services shares concerns raised by other commenters regarding the proposed intensity of need model. It is unclear how this approach will enhance service quality compared to the present system, where case managers already respond dynamically to clients' immediate needs. Under the current system, case managers increase their contact with clients and other providers when clients experience acute needs such as illness, homelessness and mental health crisis. The proposed regulations seem likely to increase staff time devoted to documentation justifying tier placement and case load compliance at the expense of meeting clients' needs in the moment.

An individual client’s needs can vary significantly over a three-month period. Inevitably the quarterly assessment of need will not be an accurate reflection of the level of services the individual might need two weeks from then. Under the current system case managers can and do adjust the intensity of service to meet the need in the moment but the new system will force case managers to focus on matching service intensity quarterly within the rigid structure of the tier system. Overall, the proposed system is unlikely to accurately reflect the evolving needs of an individual over time which makes the increased administrative burden of tracking tiers and caseloads quarterly ultimately unjustifiable.

Additionally, CSBs will be forced to commit staff time to meeting the new increased minimum face to face contacts for all clients rather than directing our limited resources toward clients' individual needs.  This burden is even greater at rural boards like ours where clients can often live in remote communities where face-to-face visits require extensive travel time. For this reason, we prefer to maintain the current minimum face-to-face and contact requirements. This approach allows us to offer a higher level of service when clients need it, instead of raising the minimum for everyone, which could restrict our flexibility to exceed these standards as needed.

We recommend pausing any changes to the current case management service until DMAS can establish a system that allows CSBs to meet clients' dynamic needs without unnecessary administrative burdens in classifying clients and tracking caseloads.

Other areas of concern:

We agree with other commenters suggestions regarding changing the registration timeframe from one business day to three.

We request greater clarification on expectations regarding how “providers must coordinate reviews of the ISP with the case manager every three calendar months.” What types of activities and documentation would be expected to demonstrate compliance with this requirement?

Thank you for your review and consideration of our feedback.