Concerning the proposed regulations which states that LMHP, LMHP-Supervisee, or LMHP-resident must complete, sign, and date an ISP:

• In order for providers to have an LMHP/LMHP-like staff member to complete ISP's they need to hire staff which can be difficult due to only having a few of these staff members in many parts of the state. Also these staff members are expensive and will be difficult to pay for, meaning providers will have to make cuts in other areas to pay for them and the work that these staff members would do does not count toward licensure supervision hours which are also hard to get.
   
• This approach to writing ISP's seems contrary to current trends due to the fact, that these ISP's could be written by staff who have very little contact with the client.

Concerning the proposed regulation requiring an authorization for Crisis Stabilization:
 

• Currently, the timeframe on receiving an approval for other services is anywhere from 2-5 days. Considering that a client is in a crisis situation when they come into this service, it does not seem very good to wait for any period of time for an authorization to be approved to begin services.
• Also, delays in the beginning of the provision of these services could lead to clients seeking more expensive and intrusive higher levels of care.
• I also support the deletion of the language that may have led to a change in the unit structure or the reimbursement rates.
  
  Concerning the regulation change in which Non-Residential Crisis Stabilization may be used as a higher level of care in the consideration of MHSS eligibility criteria:
• I support the addition of this service as a higher level of care, as the services provided in non-residential are the same as in a residential CSS, they are just provided in a different setting.