After reviewing the draft provider manual for CPST services, I have grave concerns:

• CPST presents significant financial and operational challenges for mental health agencies including not being cost effective, posing threats to both revenue stability and workforce stability.
• Reimbursement rates do not align with actual costs such as salaries, training, travel, and supervision making sustainability unrealistic.
• CPST is billed by time units; when clients cancel, reschedule, or no-show staff costs remain the same.
• There is already a severe shortage of providers in the mental health field and the requirements for CPST will only make that worse.
• Those of us living in rural areas have even more challenges.
• TDT can provide up to 25 hours of support each week and CPST is capped at 28 hours per month. This will increase the risk of academic failure, suspensions, or being placed in restrictive settings.
• CPST requires 8 hours of parent/family engagement per month. Unfortunately, the majority of children needing services do not have that kind of support which will end up preventing many children from getting the crucial support they need.

As someone who works for a community service board; I feel as though moving forward would be devasting, leaving adults and children without critical supports and put providers out of business. Please reconsider!

I attended the VACSB session on Medicaid redesign and someone very astutely asked, "What problem are we trying to solve with the new regulations for Mental Health Case Management?"  That question kept ringing in my ears as I read these draft regulations.  There is a general lack of clarity in the regulations that make it difficult to understand the overall vision for this project (beyond saving the Commonwealth money).  A few examples:

   1.  On page 4, the regs state that mental health case management does not include the provision of direct clinical services.  However, on page 7 under the heading Staff Qualifications and Requirements they require case managers to be knowledgeable of treatment modalities, intervention techniques, supportive counseling, independent living skills training, and crisis intervention.  Why should they be required to b   2.  e knowledgeable in all these areas only to be told that they should not provide these types of interventions?  It would seem DMAS has a very poor understanding of what case management looks like "in the field".  Our case managers do all of these things to the great benefit of the individuals we serve.  Which is it? Should case managers provide effective care or not?  Please clarify.

On page 5,  it is stated that the case manager shall "continuously" monitor the appropriateness of the ISP.  What is meant by continuous?  Is this an increase in the expectation for quarterly reviews every three months?  Please clarify.

   2.  On page 12, under the case load requirements section,   item 4 references the "ratios" above, but items 1-3 do not make reference to ratios.  They reference total number of cases.  The whole thing is an unnecessarily complicated classification system that will prove difficult to track in our EHR.  It seems an attempt to strip case managers of the freedom to apply their own clinical knowledge and knowledge of the individuals on their caseload to act nimbly to meet the needs of those they serve.  It also creates an onerous expectation that we will track the average hours of service that each individual receives.  This seems misaligned with the notion that the intensity of the need drives the amount of service provided.  If everyone gets an average of two hours per month of service, why do we need classifications?  Again, what problem are we trying to solve?  

3.   On page 6, what, exactly, is meant by the case manager shall "revise the ISP whenever the amount, type, or frequency of services rendered by the individual's service providers change"?  What degree of granularity is indicated here?  Does this include all service providers, both internal to the agency and external?  If this is not clear, I could see us being cited because a medication change is not reflected in the individual's ISP, or a therapist begins EMDR with a client, etc.  If that is the expectation, we really will be treating the chart more than the individual. 

We write in response to the limitation of Case Management service Medicaid reimbursement being directed to only Community Services Boards. We appreciate the opportunity to register concern with this stipulation and the associated challenges that community-based providers encounter with the provision of this service.

Gateway Homes, Inc. has been serving individuals with serious mental illness diagnoses since 1983. Over the years, we have provided a spectrum of residential support and wrap-around mental health supports that reflect over 90% year to year success rate in the community. We have worked with every Community Services Board across all regions in the Commonwealth, and we consistently observe that with few exceptions, once clients come to Gateway, the CSB exits their care. Some even disenroll their clients from their CSB services because they know that Gateway provides them regardless of their mandate to do so. In direct contradiction, CSBs appear to continue to bill Medicaid for clients they are not serving, which does not meet the published expectations of DMAS. This seems to be a major concern for waste, fraud, and abuse.

Meanwhile, Gateway continues to provide the services necessary to support the individuals to move towards their self-identified recovery and independence goals. Gateway’s case management services far exceed the expectations outlined in the chapter and we, and all other community-based providers, continue to be barred from access to the reimbursement for these services.

This gross oversight categorically denies individuals the right of choice in providers for this service, reinforces a system that does not provide the proscribed service appropriately, and continues to put the burden of mental health care on community-based providers without remuneration. At a time when DMAS is actively working towards the implementation of supposed cost neutral changes, there appears to be a disconnect between reality and funding availability. Will every CSB be required to maintain case management accreditation as part of the CPST roll out or will special consideration be levied to ensure that state agencies benefit from less expectations without sufficient oversight and more reimbursement?

We ask that DMAS review this and allow clients their freedom of choice in providers, which will thereby require:

• cooperation with DBHDS Office of Licensing for there to be an opening of gates to case management licensure,
• case management designation within DMAS portal, and
• expand client access to providers that can and do already exceed the expectations of the case management service and have better outcomes than CSBs.  

MHCM Level of Care Guidelines-Required Activities, Case Management Engagement, 2. Face to Face requirements:  The policy increases the face-to-face requirements from once every 90 days to two times every 90 days.  It also adds the requirement that one of these visits must occur in the community.  This double the face-to-face requirements and increases time spent in travel and coordination to ensure individuals are seen in the community increasing the cost to provide the service.  In addition, costs will increase due to the additional unfunded tracking and level of determination requirements.

MHCM Medical Necessity Criteria-Admission Criteria Diagnosis, Symptoms, and Functional Impairment, 2. Required LMHP documentation:  This new requirement will be challenging for kids meeting at risk criteria since often those kids have been referred to us to link them to services and have never seen any provider, especially kids under 5 where we don’t have any providers to see them. We also have a lot of SED kids referred for the purpose of starting them in services as they have never had any. We don’t/can’t diagnose them but kids come to us with a reported diagnosis by the parent/guardian and/or referral source but often tracking down documentation of that is sometimes challenging (for example a parent will tell us the kid is depressed or has ADHD but there is not always documentation that we can obtain to support that).

MHCM Medical Necessity Criteria-Continued Stay Criteria:  Previously MH Case Management was a registration-only service due to the population served.  Our MH Case Managers serve individuals with serious, persistent, chronic mental illness who often rely on these services to maintain baseline and avoid the need to access higher, more expensive levels of care.  By requiring multiple re-assessments and discharge if an individual does not continually demonstrate progress could lead to individuals not receiving this vital service to remain stable at baseline. 

MHCM Provider Participation Requirements-Staff Caseload Requirements:

• Intensity of need of the individual (high, medium, or low) is now required to be documented and reviewed every 90 days.  The definitions of levels do not align with realistic time expectations at each level.  The population we serve often have needs which are fluid and fluctuate between the three levels frequently.  The additional documentation every 90 days seems like an administrative task which is not clinically relevant.
• Caseload Maximums:  The CMs already adjust their supports naturally based on the individual's needs, having to add in the complexity of increased assessments and caseload limit monitoring is just more work.  This restrictive monitoring the size of caseloads based on extremely fluid intensity of need designation is a significant challenge/barrier to service.  The agency would have to continually move individuals between caseloads to manage maximums, which is not good or clinically appropriate care.  Further, we cover 1400 square miles in our planning district and typically try to geographically assign caseloads to maximize efficiencies and time available to provide services.  This may not be feasible with the caseload maximums leading to increased cost, increased administrative burden, increased transitions between providers for individuals, and less time available to provide quality services.
• The requirement for a minimum of two hours per individual per month across each provider’s caseload is unrealistic and restricts our ability to provide continuity of care or effectively operationalize Case Management programming.  Again, will lead increased administrative burden to manage caseloads and arbitrary transitions in care between different case managers contrary to best care.

Call to action with Caseload limits:  We recommend DMAS consider that, if a caseload max is required, that DMAS remove the current wording and replace with “no case manager will have a caseload which exceeds 60 in any given month”.  That is a clear maximum which is easily demonstrated at audit.  However, this would still allow us the flexibility to maintain continuity of care for our individuals, adjust to onboarding and offboarding of staff, adjust to unexpected staff medical leave, and still maintain a high level of services to the individuals we serve.

Overall, there has not been a clear definition of what problem DMAS is trying to solve with the proposed changes.  While there have been reference to concerns about case managers billing too many individuals leading to the levels of administrative oversight included in the draft, no data that demonstrates the frequency or extent that this has occurred has been provided (even when requested).   

The proposed changes to Mental Health Case Management (MHCM) services at RACSB will significantly impact both adult and child/adolescent populations, including the 873 individuals served last year. Key concerns include increased face-to-face requirements from once to twice every 90 days, with one visit required in the community, adding travel, coordination, and unfunded administrative burden. Additional home visit and service monitoring requirements, new documentation for medical necessity—especially for children under five or those without prior diagnoses—and continued stay criteria could limit access to essential services for high-need populations. New staff caseload requirements, including documentation of intensity of need, caseload maximums, and mandated minimum service hours per individual, impose unrealistic administrative demands, threaten continuity of care, and may lead to unnecessary transitions between case managers. To mitigate these challenges, RACSB recommends a clear caseload maximum of 60 per case manager per month, allowing flexibility while maintaining high-quality, continuous services.

The need for transferring individuals from a case manager's caseload once they reach capacity presents a significant challenge to person-centered care. Clients invest time and trust in forming a rapport with their case manager and this relationship is essential for effective support and progress. Disrupting this established connection through an administrative transfer, rather than a needs-driven one does not seem to be in the client's best interest. It undermines the very foundation of trust and continuity, causing potential setbacks and emotional distress.

The increasing emphasis on meeting predefined "intensity levels" presents a challenge to client-centered care. Spending staff time trying to ensure the client is in the right intensity level takes away from delivering optimal, individualized treatment. This system could unintentionally undermine the purpose of case management, leading to less effective outcomes for clients who deserve person-centered support.

As a clinician providing case management services through the CSB, I am just trying to understand the goals of the proposed changes.   What is not working with the current arrangement for case management and what is the plan designed to improve?

Under the Medical necessity section, the language does not include QMHP/QMHCM regarding documentation of SED/at risk or SMI.  This is contradictory from the Required Activities section that list both QMHP/QMHCM and LMHP types are able to complete the assessment documentation.    Does this mean that the SED/at risk or SMI documentation would require LMHP types to complete??  What is the purpose of this difference for that piece of documentation?

Under the Staff Caseload Requirements, several questions arise.   It states that Categories should be reviewed at a minimum of every 90 days.   Would this be the quarterly review?  Will there be another tool to use to review the category for each consumer?  Would this be additional documentation for staff providing the services?  If not the quarterly review, an additional form/assessment tool?

In addition, the categories and levels are vague.  They are subjective and open to a great deal of confusion/misunderstanding/incorrect labeling.   Reimbursement levels and number of hours required for case management activities for each level are the same at this time.  If that remains the same, what is the benefit/reason for assigning a level?

How do we manage ratios for mixed caseloads?   The weight of the caseloads could vary frequently causing individuals in services to be moved from caseload to caseload due to ratios. This would mean a consumer’s needs/preferences may not be able to be factored in as much as the caseload ratios.   This does not seem very consumer friendly or consumer centered.  Our individuals take time to build rapport and develop trust, changing caseloads frequently would impact their care.

As a manager/supervisor of case management staff, this sounds very challenging to navigate and manage for consumers and families primarily.   Various staff and locations of staff would be challenging to manage as well.     

Proposed case management caseload requirements potentially create an unnecessary administrative burden to categorize, justify, and calculate to meet particular metrics at the expense of the primary need of providing appropriate care to the individuals with established relationships with their case manager.

The proposed case management caseload requirements risk creating an unnecessary administrative burden by requiring staff to categorize, justify, and calculate caseload metrics at the expense of focusing on the primary goal — providing appropriate, consistent care to individuals who have established relationships with their case managers.

Managing ratios for mixed caseloads presents additional challenges. The varying “weight” of individual cases could cause frequent fluctuations, forcing individuals to be reassigned to different case managers solely to meet ratio requirements. Such changes would undermine consumer preferences and the stability of established therapeutic relationships. Our individuals take time to build rapport and trust, and frequent transitions would negatively impact both engagement and outcomes.

The increasing emphasis on meeting predefined “intensity levels” also shifts attention away from client-centered care. Time spent ensuring each individual is categorized correctly detracts from time that could be spent delivering individualized support and treatment.

The newly proposed documentation requirements — including recording intensity of need, adhering to caseload maximums, and meeting mandated minimum service hours per individual — introduce unrealistic administrative demands that threaten continuity of care and increase the likelihood of unnecessary case manager transitions.

Furthermore, it remains unclear what specific problem DMAS intends to address through these changes. The proposed “intensity of need” classifications (high, medium, or low), which must be reviewed and documented every 90 days, do not reflect the fluid and dynamic nature of the population we serve. Many individuals’ needs fluctuate frequently, making such rigid classifications clinically impractical.

Ultimately, the proposed system creates a complex and cumbersome classification structure that is difficult to operationalize within existing electronic health record systems and risks diverting valuable time and resources away from direct care.

Southside Behavioral Health appreciates the opportunity to provide comments on the draft Mental Health Case Management (H0023) regulations. We support DBHDS’ efforts to clarify expectations, strengthen accountability, and improve consistency across the Commonwealth. However, we respectfully submit the following concerns and recommendations to ensure these regulations are realistic, equitable, and client-centered for Community Services Boards (CSBs), particularly in rural regions such as ours. While we support the intent to improve accountability and consistency, the draft regulations do not clearly outline the problem they aim to solve or present data supporting the proposed structure. We encourage DMAS and DBHDS to clarify the intended outcomes and how these changes will improve service quality or client experience.

1. Determination of High, Medium, and Low Intensity of Need

Concern:
While the draft outlines functional impairment domains and examples, it does not establish a validated tool or standardized scoring system. This creates risk of inconsistency across providers, subjectivity in classification, and challenges during utilization review. Individual needs often fluctuate due to changes in health, housing, or support systems. The current structure assumes static categories that do not reflect this fluidity. We recommend flexibility in documentation requirements to avoid unnecessary reclassification and disruption of services.

Recommendation:

• Adopt or endorse a validated statewide tool to guide intensity level determination.

• Establish a standardized protocol with required documentation points to ensure uniformity across CSBs.

• Require inter-rater reliability training to promote consistency and fairness in client categorization.

2. Professional Language in Regulatory Text

Concern:
The phrase “History of falling through cracks of service systems” in the high-intensity category is stigmatizing and unprofessional. It implies fault lies with the individual rather than with systemic barriers.

Recommendation:

• Replace with: “History of unmet service needs due to barriers in system navigation or coordination.”

• This wording more accurately reflects systemic issues while maintaining dignity and respect for clients.

3. Workforce Training and Capacity

Concern:
The draft regulations outline extensive staff qualification requirements but do not include a structured approach for training, competency development, or retention. Effective case management requires ongoing skill-building in areas such as service coordination, documentation, and system navigation. Without standardized training and opportunities for professional growth, CSBs risk variability in service quality and increased staff turnover.

Recommendation:

• Establish a DBHDS-approved training and certification program for Mental Health Case Management staff, including initial and annual competency requirements.

• Provide funding or access to statewide training resources to ensure consistent knowledge and skill development across all CSBs.

• Implement ongoing professional development opportunities to promote staff retention and reinforce best practices in case management.

• Encourage DBHDS to recognize and track continuing education as a quality metric that supports workforce stability and service excellence.

4. Service Authorization and Administrative Timelines

Concern:
The requirement to submit a registration within one business day of admission creates administrative challenges for rural providers with limited staff or technology barriers. Failure to meet the deadline changes the service start date, resulting in potential revenue loss and service disruption.

Recommendation:

• Extend the registration window to three business days.

• Permit retroactive corrections when documentation supports timely service initiation.

5. Billing Limitations in Institutional Settings

Concern:
The limitation of billing case management during only two non-consecutive pre-discharge periods per year may not reflect the realities of individuals with recurring hospitalizations. These individuals often require ongoing community case management to reduce readmission risk.

Recommendation:

• Increase flexibility to allow billing for additional periods when clinically justified.

• Provide clear guidance on documenting case management roles without duplicating institutional discharge planning.

Thank you for the opportunity to comment. We look forward to collaborating with DBHDS on finalizing regulations that strengthen quality, equity, and access across Virginia’s behavioral health system.

Regarding the level of intensity tiers, caseload requirements and contact minimums:

Rockbridge Area Community Services shares concerns raised by other commenters regarding the proposed intensity of need model. It is unclear how this approach will enhance service quality compared to the present system, where case managers already respond dynamically to clients' immediate needs. Under the current system, case managers increase their contact with clients and other providers when clients experience acute needs such as illness, homelessness and mental health crisis. The proposed regulations seem likely to increase staff time devoted to documentation justifying tier placement and case load compliance at the expense of meeting clients' needs in the moment.

An individual client’s needs can vary significantly over a three-month period. Inevitably the quarterly assessment of need will not be an accurate reflection of the level of services the individual might need two weeks from then. Under the current system case managers can and do adjust the intensity of service to meet the need in the moment but the new system will force case managers to focus on matching service intensity quarterly within the rigid structure of the tier system. Overall, the proposed system is unlikely to accurately reflect the evolving needs of an individual over time which makes the increased administrative burden of tracking tiers and caseloads quarterly ultimately unjustifiable.

Additionally, CSBs will be forced to commit staff time to meeting the new increased minimum face to face contacts for all clients rather than directing our limited resources toward clients' individual needs.  This burden is even greater at rural boards like ours where clients can often live in remote communities where face-to-face visits require extensive travel time. For this reason, we prefer to maintain the current minimum face-to-face and contact requirements. This approach allows us to offer a higher level of service when clients need it, instead of raising the minimum for everyone, which could restrict our flexibility to exceed these standards as needed.

We recommend pausing any changes to the current case management service until DMAS can establish a system that allows CSBs to meet clients' dynamic needs without unnecessary administrative burdens in classifying clients and tracking caseloads.

Other areas of concern:

We agree with other commenters suggestions regarding changing the registration timeframe from one business day to three.

We request greater clarification on expectations regarding how “providers must coordinate reviews of the ISP with the case manager every three calendar months.” What types of activities and documentation would be expected to demonstrate compliance with this requirement?

Thank you for your review and consideration of our feedback. 

The proposed caseload requirements will seemingly increase the case managers' administrative tasks to include categorizing, justifying, and calculating caseload metrics, but at what cost?  What will be minimized is the case managers' ability to provide appropriate, consistent care to the individuals they serve and have established good working relationships.

Managing ratios will pose another problem - the varying weight of individual cases could cause frequent fluctuations forcing individuals to be reassigned to different case managers solely to meet the ratio requirement.  This would affect the individuals' preferences and consistency of working with those they have established trusted therapeutic relationships.  It takes time to establish this type of rapport and trust from individuals, and frequent transitions would negatively impact both engagement and outcomes.

Many of these proposed changes would deviate from individual person-centered care which seems to take us back instead of forward in terms of progress.

The proposed system creates a complex and cumbersome classification structure that is difficult to operationalize within existing electronic health record systems and risks diverting valuable time and resources away from direct care.

I agree with others in that it is still unclear why these changes are recommended or necessary.

We support some changes that align with quality improvement. We have concerns about dictating caseload sizes in this way. In the field, a caseload is never purely one level of need nor are individuals in services in the same phase of recovery across a caseload. We would request additional guidance and definitions to establish a formula for which to follow. However, this is concerning as this represents additional unfunded administrative burden. Also, we have concerns about requiring both the CNA and the CANS, the length of assessment time is already overwhelming for individuals and families. Additionally, we would support a separate or increased billing rate to account for the additional staff time.

The increasing emphasis on meeting predefined “intensity levels” also shifts attention away from client-centered care. Time spent ensuring each individual is categorized correctly detracts from time that could be spent delivering individualized support and treatment.

The newly proposed documentation requirements — including recording intensity of need, adhering to caseload maximums, and meeting mandated minimum service hours per individual — introduce unrealistic administrative demands that threaten continuity of care and increase the likelihood of unnecessary case manager transitions.

Furthermore, it remains unclear what specific problem DMAS intends to address through these changes. The proposed “intensity of need” classifications (high, medium, or low), which must be reviewed and documented every 90 days, do not reflect the fluid and dynamic nature of the population we serve. Many individuals’ needs fluctuate frequently, making such rigid classifications clinically impractical.

Ultimately, the proposed system creates a complex and cumbersome classification structure that is difficult to operationalize within existing electronic health record systems and risks diverting valuable time and resources away from direct care.

I work in a Outpatient Program with a CSB, and I have some concerns about the proposed MHCM Level of Care Guidelines and the new Intensity of Need model. I understand the goal is to improve service quality and accountability, but I’m worried that the way these changes are structured could actually make it harder for staff to do their jobs and for clients to get the care they need.

Right now, case managers are able to adjust the level of service based on each client’s needs. If someone is going through a crisis, like homelessness, health issues, or a mental health emergency, we can increase contact, coordinate with other providers, and respond in the moment. The new model seems to focus more on paperwork and following strict guidelines than on actually helping clients when they need it most.

The increased face-to-face requirements—doubling the number of contacts every 90 days and requiring at least one to be in the community—will take a lot of extra time and travel. For clients who live far away or in rural areas, this will make it harder to spend time on coordination, crisis response, and other important work. Raising the minimum for everyone may also limit our ability to give extra attention to clients who really need it.

The proposed caseload rules also worry me. Categorizing, justifying, and calculating caseload metrics will take time away from direct client care. Mixed caseloads make it even harder—clients might have to switch case managers just to meet ratio rules. That could disrupt trust and rapport, which take a long time to build.

Finally, the “intensity of need” classifications (high, medium, low) that have to be reviewed every 90 days don’t reflect how quickly a client’s needs can change. People’s situations can shift week to week, or even day to day. Rigidly sticking to these categories feels unrealistic and could create extra paperwork without actually improving care.

Overall, I’m concerned that these changes would pull staff away from direct support and make it harder to provide the kind of flexible, responsive care our clients need.

The first and highest concern is the requirement to meet clients in the community at least once every 90 days "outside of a CSB". There is no language that takes into consideration inclusion of the client's choice. This runs directly opposed to the language about the ISP being "person centered". It also does not consider recovery model planning (least restrictive) and forces a meeting in a location where the client may not want to meet and/or is not appropriate for the persons level of functioning. The location of services should always be a clinical assessment and agreement between the clinician and the client. Does the client declining meeting in the community force them to be ineligible for and/or discharged from the service? 

The second concern is the caseloads and hours. As it is written, it seems that there will need to be a tremendous amount of calculations being done by managers and/or QI departments to calculate caseloads and average hours and have that contingent on assessed CM intensity. This would be a constantly moving target given client's level of need and intensity can change frequently. This introduces unnecessary and unhelpful distraction for providers and could cause harmful transfers which disrupts the provider/client relationship. 

Please see the comments below submitted on behalf of the Virginia Beach Department of Human Services (VB CBS) regarding proposed changes to Mental Health Case Management.

Face-to-Face and Community Contacts

The current requirement of one face-to-face contact per quarter is more manageable than the proposed two face-to-face contacts for case management services. This doubles the requirement and is unlikely to be well-received by some individuals and families served. We ask you to consider that many of them already find it difficult to meet once each quarter. Doubling this requirement may increase scheduling difficulties, but we recognize that this is not the case for every individual and family.

While we understand the benefits of seeing individuals across settings (and are in many instances doing so successfully), requiring one of the face-to-face events to be in the community does not seem to account for the individual’s right to choose and their needs. Many individuals and families are protective of their privacy and may prefer to meet only at the office. Additionally, many face transportation challenges. This could discourage some individuals and families in need from accessing services.

The adult population we serve is often seen in the community. Perhaps consideration could be given to allowing some face-to-face appointments in the office, such as before or after medication management visits, for example. This may help improve continuity of care.

Revisiting the availability of mental health skill-building services to ensure that case management requirements are not further stretched should be seriously considered. It appears that some of these requirements are being integrated into case management tasks. A cost analysis might also be beneficial.

Assessing CM Levels of Intensity

The descriptions of how we categorize service intensity for individuals are heavily focused on the adult population. High, medium, or low are very subjective guidelines and could be confusing for families moving between localities. We suggest that more consideration be given to the child and adolescent population. For instance, an individual deemed to have a low level of need might, in fact, have parents who struggle with system navigation and daily activities. In such cases, their needs could be categorized as high. Conversely, someone appearing to have a high level of need might have parents who are very experienced with navigating systems and require only minimal assistance.

Tiered CM could introduce additional barriers for CSBs serving the BH population, as they don’t consistently maintain the same level of acuity during service. LOC is already monitored regularly and appropriately. It would be burdensome to constantly reassess the level if the billing structure does not support funding for frequent assessments and other related activities/requirements. An assessment that accurately determines the level of need, service frequency, and caseload size is essential. What flexibility, if any, will be permitted for sudden changes in caseload intensity?

Tracking Time Spent Based on Intensity

Requiring CSBs to track and report the average service time per individual each month is burdensome and subjective. How does providing a minimum of two hours per individual relate to their service intensity? If only 1.75 hours are provided but all other billing requirements are met (face-to-face contacts, collateral contacts, etc.), will CSBs be unable to bill? Also, the current reporting structure should be reviewed and updated to ensure accurate tracking.  

It was refreshing to see several of the same concerns about the redesign in reference to case management services. The theme of (1) increased administrative burden (2) taking away opportunities for direct services to individuals served and (3) lack of person centered services stood out and seems to stretch across most CSB’s. It would be appreciated that these comments are taken in consideration and appropriately addressed for further clarification for the staff providing the services.