Continued from comment 1:

Recommend that timeframes be established regarding when DBHDS responds to CAPs, questions, applications. Recommend that responses from DBHDS are in writing and can be shared among CSBs. 

In regards to inaccuracies on licenses, MCOs rely on published license addendums.  Inaccuracies result in financial impact to CSBs.  License updates need to be expedited to support a more rigorous preauthorization and billing process from MCOs.

Program staff , those providing direct services, are spending more time reporting incidents, involved in RCAs, responding to various investigative units, DBHDS licensure specialists, as well as submitting various review documents as requested and which has a direct impact on actual service delivery.  The reporting and monitoring for providers is significant.  In light of these regulations and other initiatives a coordinated study of the full impact of requirements by OL, OHR and program specific areas on providers is recommended.