Gaps in service: currently require new Comprehensive Needs Assessment if no services in 31 days. Recommend changing this to need Comprehensive Needs Assessment Update. Many states use abbreviated CNA Update Form for people re-entering services any time less than 1 year.  Historical items on the assessment should not change. Using an "Update" to the assessment is used in several other states for any clients re-entering services within one year. 

Comprehensive Needs Assessment: If ISPs are reviewed every 90 days, quarterly reviews are required, and a new ISP is due every year, recommend discontinuing needing a new annual Comprehensive Needs Assessment due to duplication.