As a behavioral health provider, I too, share the concerns that my colleagues have stated regarding the proposed regulation changes pertaining to Intensive In-Home Services.Removing case management from the scope of Intensive In-Home services would be a disfavor to the individuals and families receiving services and would not be best practice.   Doing so would require that individuals add yet another provider to what can already be a complex treatment team in order to receive case management services that are so often needed.    Research shows the need for a multi-systemic and collaborative approach when working with children and their families which case management is an integral part of.   However, by soley allowing CSB’s to provide this service we would be fragmenting treatment even more and making it more difficult for individuals to get connected to the services they need in a timely manner.   I concur with Youmell’s concerns about the CSB’s capacity to meet case management needs of Intensive In-Home individuals.  By definition, Intensive In-Home services are time limited and provided to individuals who are currently at-risk.  How would case management services through a CSB address this immediate need if it typically takes a month or more just to get in for an initial case management session?  Additionally, because of the current caseload CSB Case Managers have, they are unable to provide the intensive level of case management services needed for these individuals who are at-risk.  By leaving the current definition of case management services, it would allow individuals and their families to have increased access to the services they need in at the intensity/frequency they are needed in order to prevent an out-of-home placement which is the ultimate goal.  In addition, it would streamline the process for the families rather than adding the requirement of an additional step and provider.