The proposed implementation of the CANS Lifetime assessment raises several concerns.

It is unclear whether the CANS Lifetime replaces or supplements the Comprehensive Needs Assessment (CNA). If it replaces the CNA, clarification is needed regarding whether it satisfies current DBHDS licensing requirements for an initial comprehensive assessment. If it supplements the CNA, providers will face duplicative assessment requirements.

Additional clarification is requested regarding:

• Availability of the CANS Lifetime tool for provider review.
• Required frequency of reassessment.
• Training costs, duration, and recertification requirements.
• Use of CANS completed by another provider within the previous 12 months while simultaneously meeting licensing requirements.
• The role of CANS during tier transitions and post-step-down monitoring.