Section: 6.3 Provider Accreditation

• Will a CPST specific accreditation be required or if we are currently accredited by CARF, is that sufficient?

Section: 7.6 Continued Stay Criteria

• How is “not making sufficient progress” measured to trigger need for alternative service plan within 180 days.  How does this support the needs of individuals with chronic, persistent, serious mental illness.  The authority given to Managed Care Organizations to override plans created by the team and agreed to by the individual should be reconsidered. 
• How does the requirement of expectation of improvement at current level of service if individuals are at baseline but still meet the eligibility criteria?