Sec 5.2.1 The ISP review shall be completed face-to-face and shall include a LMHP/LMHP- type, additional CPST team members and the individual, and family/caregiver, if clinically appropriate.:  Does this mean a full on team meeting every 90 days, or just a review with the client and their direct staff which can be signed off on by the LMHP? 

Sec 8. 7 Stepdown Services : If an individual has remained at the same Level of Need for 18 calendar months without improvement, the provider shall notify the individual's MCO and, in coordination with the MCO, develop a plan to refer the individual to an appropriate evidence-based practice, as set forth in Section 3.2 and Section 8.6 (Continued Stay Criteria). Documentation of this referral process shall be maintained in the individual's record, and the ISP shall be updated to reflect the plan: This wording makes it seem like the individual has no choice in their services changing. What if the individual doesn’t want to be referred elsewhere? What is the plan for if an individual declines to accept new services? Is the intention to discharge them regardless of their preferences?

Psychosocial Rehab is still on the list of exclusionary programs (can’t have that and CPST) but if the idea is to eliminate Psychosocial Rehab, does this actually mean clubhouse, or is clubhouse allowed? Please Clarify.

Overall these regulations continue to present an administrative burden on LMHP types which will lead to a higher level of burnout. There is also too much ambiguity in some of the wording, and still too much reliance on the MCO's.

Why does the MCO need to be notified if an individual contacts 988? Why is it on the provider to coordinate with the MCO to find appropriate services? 

"The individual’s MCO/FFS service authorization contractor conducting the service authorization review may approve the requested service(s) or may recommend a more clinically appropriate service based on their review."  Why do they have the ability to deny services if they feel a whole team of providers are wrong? We all know they don't want to actually pay for anything. All of these policies make it harder to get anything done from the provider standpoint, and seem like they are intentionally putting barriers in place to justify denial of care.