The updated requirements hold some continued concerns:

• SMI/SED/At Risk definitions are slightly different than other regs
• Community face-to-face including workplace--this may be inappropriate and unwanted due to privacy concerns, unless in a supported employment situation.
• providers must coordinate reviews of ISP with the CM every 3 calendar months--the wording is confusing.  Should this be the responsibility of the provider or the CM? 
• ISP updates with changes in amount, type, or frequency of services rendered--should this be in the counselor's/provider's ISP rather than the CM ISP? 
• We support changes in regards to tiers and caseloads; however, tracking when caseloads go over 45 and addressing with a plan to reduce would have to be per CM, which is manual and complex, taking away supervision time.