The CSB recommends maintaining flexibility, preserving the stand-alone MHCM, supporting workforce capacity, and ensuring alignment with crisis systems.
The CSB recommends a phased 12–24-month implementation timeline because successful implementation will require policy updates, staff training, EHR modifications, and coordination across multiple service systems. Without sufficient time, providers may face operational disruptions and reduced capacity to serve individuals. Given concurrent redesign across multiple behavioral health services, a phased timeline is necessary to avoid system strain and ensure continuity of care.
Client Choice and Person-Centered Care: The CSB emphasizes the importance of preserving client choice in service delivery. Individuals should have the flexibility to choose the location, modality, and level of engagement for case management services based on their preferences and clinical needs. The CSB supports maintaining the current MHCM contact framework with modality flexibility based on client preference and clinical need. Some individuals may be uncomfortable receiving services at home or in public settings, while others may prefer telehealth or less frequent contact. Requiring that the service location be explicitly aligned with the ISP may add an additional documentation burden and limit flexibility in selecting appropriate meeting locations.
Policies that mandate specific service modalities or locations may unintentionally override client choice, reduce engagement, and create barriers to care. This is especially important for youth and individuals with privacy, cultural, or stigma-related concerns. The CSB recommends that service requirements support, rather than restrict, person-centered care and allow providers to tailor service delivery to individual preferences. The CSB also recommends strengthening family-centered language and expectations across MHCM activities for youth and children.
Preservation of Stand-Alone MHCM: MHCM remains a foundational service that supports individuals with complex needs through care coordination, system navigation, and continuity of care. However, the draft does not fully address the unique needs of youth, which require greater coordination with families, schools, and community systems, as well as more flexible engagement strategies. The lack of youth-specific guidance on caseload expectations, family involvement, and school coordination may increase administrative burden and reduce staff capacity.
Additional clarification is recommended to support effective coordination and continuity of care for youth and transition-age populations. Stand-alone MHCM should remain a viable service when an individual’s primary need is coordination rather than rehabilitation, because limiting MHCM risks creating service gaps.
Caseload and Workforce Risk: High caseload expectations, combined with increased documentation, coordination, and engagement requirements, already strain workforce capacity. Although the draft does not establish a formal caseload requirement or cap, operational benchmarks such as 45 individuals per case manager may be infeasible under expanded expectations. As non-billable responsibilities increase, providers may need to reduce caseload sizes to maintain compliance, which can decrease access to care and lengthen wait times for services. This reduction in effective caseload capacity may affect access to services across the system.
The CSB also notes that the draft does not address youth-specific caseload considerations. Youth case management requires greater coordination with families, schools, and community systems, resulting in higher time demands per individual. Without recognizing these differences, staff capacity may be further reduced, limiting access to services for youth and families.
Financial Sustainability: Increased expectations for documentation and coordination create additional non-billable workload that may not be reflected in reimbursement structures, thereby risking long-term service sustainability.
Coordination with Other Services: The CSB recommends removing or revising the limitation to two pre-discharge periods within a 12-month period, as this restriction does not align with the needs of individuals experiencing multiple or prolonged hospitalizations. These limitations may reduce support for safe discharge planning and increase the risk of delayed discharges, service gaps, and hospital readmissions.
The CSB also recommends including MHCM guidance tailored to youth that outlines coordination expectations with systems such as schools (IEPs), juvenile justice, DFS/foster care, wraparound supports, and family engagement. Additional guidance is needed for transition-age youth to ensure continuity of care as they move from youth to adult systems.
The draft does not establish a formal tiered model for MHCM services. If acuity-based or tiered case management approaches are intended, additional guidance will be needed to define criteria, expectations, and system support to ensure consistent application across providers. Without clear guidance, tiering may be applied inconsistently, leading to variability in service delivery and documentation expectations.
Crisis System Alignment: Policies should reinforce, not disrupt, the use of Emergency Services and Mobile Crisis systems. Case managers must retain the ability to refer immediately to appropriate crisis services without delay or conflicting service requirements.
EHR and Administrative Burden: Changes will require updates to EHR workflows, including documentation requirements, potential tier classification, and service location tracking. Increased documentation expectations may also create audit and recoupment risk if applied inconsistently across providers and payers. Sufficient implementation time is necessary to support system build, training, and consistent application.
System-Level Impact: Simultaneous redesign across services increases the risk of system strain, reduced provider participation, and decreases access to care if not implemented in a coordinated, phased manner.
Without these adjustments, the combined effect of these requirements may reduce provider capacity, limit access to care, and create unintended barriers for individuals and families seeking services.