I am concerned that implementing a 20-hour limit on treatment services could create unnecessary barriers for individuals who require more intensive care. Treatment decisions should be guided by each client’s clinical needs, progress, and medical necessity rather than a standardized hourly limit.

Although I recognize that providers may request authorization for hours beyond the proposed limit, this additional administrative step could delay access to essential services and place an unnecessary burden on providers, clients, and their families. For individuals who depend on consistent, intensive treatment to make meaningful progress, such delays may have significant consequences.

I encourage DMAS to prioritize individualized, evidence-based treatment recommendations and ensure that qualified clinicians retain the ability to determine appropriate treatment intensity based on medical necessity. Policies governing service delivery should support timely access to effective care rather than create administrative obstacles that may compromise client outcomes.

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