In regards to the below in the treatment planning section on page 4 of 15

• Diagnoses, symptoms, challenges, and functional impairments indicating the need for the services

I would recommend changing the "and" to an "or" as the ongoing nature of the assessment and benefits of treatment would mean that as treatment continues some of these symptoms, challenges, or functional impairments may no longer be present yet treatment would need to continue to resolve other concerns. Language in the regulation that requires all of these to be listed, despite an individuals improved health status, could become a regulatory issue.