We support some changes that align with quality improvement. We have concerns about dictating caseload sizes in this way. In the field, a caseload is never purely one level of need nor are individuals in services in the same phase of recovery across a caseload. We would request additional guidance and definitions to establish a formula for which to follow. However, this is concerning as this represents additional unfunded administrative burden. Also, we have concerns about requiring both the CNA and the CANS, the length of assessment time is already overwhelming for individuals and families. Additionally, we would support a separate or increased billing rate to account for the additional staff time.