Relationship Between Continued Stay & Concurrent Authorization
It would be helpful to clarify how the continued stay criteria in Section 8.6 relate to the concurrent authorization requirements in Section 10. Is meeting the continued stay criteria sufficient for reauthorization, or are there additional concurrent authorization requirements providers should be meeting? 

Concurrent Authorization: ‘Not Progressing’
The term not progressing is very subjective. Is this intended to remain a clinical determination by the provider, or will there be objective criteria that providers should use to support services and reauthorization?

Clinically Inappropriate Delay (Page 34)
A little more guidance around what would be considered a "clinically inappropriate delay" would be helpful. What types of situations is this provision intended to cover?

18 Month Timeframe
Is the 18 calendar month timeframe cumulative across providers, or does it reset if an individual changes providers or experiences a break in services? Additionally, if an individual's LON later decreases, does the authorization timeframe return to 6 month authorization periods? It would also be helpful to clarify how providers are expected to determine an individual's prior length of CPST participation, particularly if caregiver or individual report differs from the actual duration of previously billed CPST services.

Caregiver Involvement
How does this requirement apply to youth who are legally able to consent to their own behavioral health treatment, or when family/caregiver involvement is not clinically appropriate or reasonably feasible? It would be helpful to clarify that reauthorization will not be negatively impacted when providers have documented reasonable efforts to engage caregivers, but participation remains limited for reasons outside the provider's control.