I recommend that the following revisions are made to draft regulations for ACT services:

1.  The ACT team shall have 24-hour responsibility for directly responding to psychiatric crises...the team shall be the first-line crisis evaluator and responder for individuals served by the team.  1) This regulation would force PACT teams to respond in person around the clock which would have a negative impact on staff retention; 2) ACT services are heavily based upon rapport with the individual.  Having the ACT worker serve as the prescreener and evaluator will potentially impair relationships built with individuals served; 3) Many ACT team workers are not prescreeners and doing so would force clinicians to focus on crisis management as primary role on the team.

2.  DMAS considers LMHP and LMHP-E to be equivalent in terms of allowances related to service provision.  Please change language to allow LMHP and LMHP-E to be used interchangeably.