Thank you for the opportunity to provide comment regarding Sections 3.2 and 4 of the proposed guidance, specifically the requirement that the Individualized Service Plan (ISP) be authorized and overseen by either the Clinical Director or Program Director.

ISP Oversight Requirement (Sections 3.2, 4):
Requiring the Clinical Director or Program Director to oversee and authorize all ISPs will create a significant burden on our system and is not feasible with our current staffing structure. In most community-based programs, Clinical Directors and Program Directors are removed from direct service delivery and primarily focus on administrative, operational, and compliance responsibilities. They are not the individuals most familiar with the day-to-day needs, progress, and challenges of each member.

Qualified Mental Health Professionals (QMHPs) are the appropriate staff to oversee ISPs.
QMHPs have the practical, hands-on knowledge required to develop and oversee service plans. They work directly with members, understand their needs, and are best positioned to ensure that ISPs are accurate, person-centered, and clinically appropriate. Restricting this responsibility to high-level administrative staff will slow down workflow, create bottlenecks, and increase the risk of delays in service delivery.

This requirement will ultimately reduce efficiency, limit responsiveness, and place strain on programs that already operate with tight staffing ratios. Allowing QMHPs to continue overseeing and updating ISPs is essential for maintaining timely, high-quality care.

We respectfully request reconsideration of this requirement and recommend reinstating QMHP responsibility for ISP oversight to reflect the operational realities and best practices of community-based mental health services.