Thank you for including MST in this round of enhancements.  We have a few questions and suggestions related to the proposed regulations:

1. Will there be consideration to continue the use of MST weekly notes as the primary document for recording information with a weekly log attached, as a way to capture individual contacts, rather than having individual notes for each contact?   On pages 18 and 19, in the book “Multisystemic Therapy for Antisocial Behavior in Children and Adolescents,” it indicates that

“A system of communication has been developed to help therapists convey important clinical information to supervisors, which in turn, the MST team passes along to the team consultant. To help therapists save valuable time, the conceptual aides are designed to convey essential case information in formats that support the underlying MST clinical process while minimizing the amount of written text.”

2.  On page 12 of App D it indicates: 

"4) Within the past 30 calendar days the youth has been or is at risk of being admitted to an inpatient, partial hospitalization, residential crisis stabilization unit, residential level of care, ARTS ASAM Levels 2.5, 3.1, 3.3, 3.5, 3.7 or 4.0 OR is being discharged from one of these settings and demonstrated the above admission criteria prior to placement;"

At risk of psychiatric hospitalization is not a stand alone requirement for MST services admission criteria by the developers.  We recommend editing the criteria to indicate "at risk of out of home placement to psychiatric hospital, detention or foster care".