Ch IV. p. 13 "DBHDS licensed providers who are implementing the Daily Living Activities (DLA)-20 may use the DLA-20 as the Comprehensive Needs Assessment as long as the DLA-20 is performed by an LMHP, LMHP-R, LMHP-RP or LMHP-S, all 15 elements for the Comprehensive Needs Assessment are captured as well as all requirements are met as set forth in this manual. " A qualified mental health case manager is allowed to complete CNA for case management services only in current regulation. Please update language to clearly reflect that a qualified mental health case manager may also utilize the DLA-20 as the CNA (consistent with above guidance for LMHP) if case management is the only service being provided. 

Ch IV. p. 21- "If a CMHRS or EBH service has not been initiated for more than 31 days and the Comprehensive Needs Assessment is outdated as defined above, a new Comprehensive Needs Assessment is required to initiate CMHRS or EBH services. " Please consider allowing an addendum to be completed if a service does not begin within 31 days rather than a full CNA. Requiring a client and family to complete a full CNA after 32 days is a significant administrative burden and not person-centered. An addendum would adequately capture needed clinical information for service delivery and treatment planning.