I am submitting this comment to provide feedback on the proposed draft update. While I support efforts to improve service quality, I am concerned that several of the proposed changes may create unintended barriers to care, reduce access to services, and negatively impact both individuals and the case management workforce.

1. Face-to-Face Contact Requirements

• Requiring two face-to-face contacts every 90 days, including one in a community setting, may not be feasible for all individuals.
• Some individuals struggle with public outings, prefer staff not in their homes, value privacy, or have behavioral/safety concerns.
• Mandating these contacts for all could reduce access to needed services.

2. Documentation Expectations

• Increased documentation requirements may create administrative burden.
• Could reduce time for meaningful engagement and individualized support.
• May contribute to staff burnout and turnover.

3. Client and Family Involvement

• Mandating family participation for every review may be impractical.
• Some individuals prefer privacy or lack family support; strained dynamics may exist.
• Could compromise autonomy and participation.

4. Linkage to Resources

• Some individuals only require monthly monitoring and do not need resource linkage.
• Resources are limited in many communities, making universal linkage unrealistic.
• Mandatory linkage could divert focus from critical individualized support.

5. Workforce and Service Continuity

• Proposed changes may overwhelm staff and increase turnover among experienced case managers.
• Could reduce continuity of care, timeliness of services, and overall support for individuals.

6. Service Registration Timeline

The next concern is regarding the expectation that new case management service registrations be submitted within one business day. While timely submission is important, this requirement may not be realistic given the scope of responsibilities case managers carry.

Case managers must balance direct service delivery, coordination with providers, and documentation requirements. In many cases, additional time is needed to ensure that all required information is accurate and complete prior to submission.

Additionally, factors such as limited availability of individuals, delays in obtaining information, and coordination with other providers can impact the ability to meet a one-day deadline.

Recommendation: A more flexible timeframe, such as 5-10 business days, would better support accurate submissions and allow case managers to maintain quality service delivery while remaining compliant.

Thank you for considering these recommendations:

• Maintain flexibility in face-to-face frequency and modality.
• Keep documentation clinically relevant and focused.
• Encourage, but do not mandate, family involvement.
• Recognize resource limitations and individual needs.
• A more flexible timeframe for service registrations.

These changes would help ensure that case management services remain accessible, individualized, and sustainable for both individuals and providers.