Thank you for providing the opportunity to comment on the proposed changes. 

6.1 Service Authorization

The proposed regulation states providers must submit a registration to the individual's MCO or FFS service authorization contractor within one business day of admission.  Recommend reconsideration of the requirement for submission within one business day. While we understand the importance of timely authorization, this timeframe may not be operationally feasible in all circumstances.

2.3.1 Case Management Engagement

The proposed regulation states at least one face-to-face contact shall occur in-person at a natural community-based setting outside of the CSB location (e.g., the individual's home, workplace, or other community value. Recommend reconsideration "at a minimum, the case manager must offer to visit the individual once every 90 calendar days in a natural community-based setting. The response from the individual and any barriers shall be documented within the record to reflect the preference of the individual. 

2.4.2 Continued Stay Criteria

The stability of the individual is not being addressed in the continued stay criteria. Recommend reconsideration to add or provide clarification on existing language to include the need for stability of the individual. 

2.5.3 Staff Caseload Requirements

The proposed regulation states the caseload of a full-time case manage shall not consistently exceed 45 individuals as evidenced by the average number of individuals on the case manager's caseload over the most recent six months. Recommend adding language that the number of individuals assigned to a case manger shall be based on the level of care an individual requires as individual's needs may vary, flexibility is essential to managing caseloads and tracking & addressing when caseloads go over 45 will be an administrative burden that will take away from supervision time. 

2.3.3 Service/Supports Planning and Monitoring

Providers must coordinate reviews of the ISP with the case manager every three calendar months.  Recommend clarifying the requirement either provider or CM. 

Revise the ISP whenever the amount, type, or frequency of services rendered by the ISP providers change. Recommend reconsideration as the provider requirement and not the CM requirement.