There are a few concerns alongside some of the other comments that I have read through so far.

1. LMHP Documentation Review Requirements and Administrative Burden
There is clarification needed on whether LMHPs are required to review and/or co-sign all documentation completed by non-licensed staff. As written, the draft suggests a high level of ongoing clinical oversight, which appears to include regular review of progress notes and service documentation.

When considered alongside the additional LMHP requirements—

• weekly supervision of non-licensed staff,

• weekly team case reviews,

• quarterly reviews (QRs),

• ongoing assessment and ISP oversight, and

• 24/7 on-call availability for crisis consultation—

this expectation represents a significant administrative and operational burden on LMHPs. We are concerned about the sustainability of these cumulative responsibilities, the impact on clinical capacity, and the potential risk to timely service delivery if expectations are not clearly defined and appropriately scaled.

Clarification is requested on:

• Whether all non-licensed documentation must be reviewed by an LMHP,

• The required frequency and format of such reviews, and

• Whether co-signature is required for every note or only at defined intervals.

2. Weekly Supervision Requirements vs. Team Meetings
The draft indicates weekly supervision requirements for non-licensed staff. Please clarify on whether existing weekly team meetings, case staffing meetings, or interdisciplinary rounds may satisfy this requirement, or whether separate, individual supervision sessions must be conducted and documented in addition to team-based meetings.

This distinction has substantial implications for scheduling, staff capacity, and administrative workflow, and clear guidance is needed to ensure compliance without duplicative processes.

3. Program Supervisor Title Requirements and Role Alignment
There is language suggesting changes or standardization of program supervisor titles. This presents challenges as our organizational structures and HR frameworks are aligned to established roles and titles.

4. Level of Care Changes and Clinical Fluidity
As is common in community-based services, individuals’ levels of care can change based on a variety of clinical factors including stabilization, decompensation, hospitalization, engagement, or life circumstances.

• How transitions between CPST tiers will be operationalized in real time,

• Whether new service authorizations will be required each time a level of care changes, and

• How continuity of care will be maintained during these transitions to avoid service gaps or delays.

5. CAHN Assessment Timeline
Has a projected timeframe been established for the completion and release of the CAHN assessment? This information is critical for workforce planning, role design, and program implementation decisions.

6. Transition of Current Clients / Grandfathering / Authorization Process
We are also seeking direction regarding how current clients and cases will be transitioned into the CPST model:

• Will existing clients be grandfathered into the new service structure?

• Will new service authorizations be required for all current clients?

• Will agencies be expected to reassess and tier all current clients prior to transition, or will there be an automatic conversion process?

Given the volume of clients served and the clinical complexity of many cases, this process will require significant planning and clear guidance to avoid disruption in services.