The following summarizes feedback regarding the "Service Authorization" section received from our members since the draft policy was released:

Authorized Units and Service Intensity

• The proposed maximum units and hours per week/month for both Tier 1 and Tier 2 are far too low to meet the needs of the target population, given their ongoing emotional and behavioral challenges.
• Providers are unclear how authorized units will be divided among different staff roles, raising operational and billing uncertainty.
• The limited authorized time does not align with the complexity of the cases or the intensity of support required.

Authorization Process and Timing

• The requirement for preservice and concurrent authorizations with short turnaround times (i.e., submission within one day) is unrealistic, especially when providers must evaluate for potential EBPs before authorization.
• Concern that initial assessments may not be reimbursed if the authorization is delayed beyond the narrow window.
• The requirement to include a signed ISP at the time of authorization submission adds administrative burden and could delay service initiation.
• Unclear how retroactive requests will be handled under these new timelines.

Tiering Criteria and MCO Discretion

• The tier and level system (Tier 1–2; Levels 2–6) is overly complex and subjective, leaving room for inconsistent MCO interpretation.
• Providers fear MCOs will default to the lowest unit tiers to minimize cost, even for high-need clients.
• Requests for clear examples of what distinguishes Tier 1 vs. Tier 2 and how Level 2–6 criteria differ in practical terms.
• These tiering ambiguities directly affect staffing models, service planning, and reimbursement predictability.

Summer Programming Restrictions

• Requiring discharge at the end of the school year eliminates summer continuity of care and undermines clinical progress.
• Loss of summer services may lead insurers to deny reauthorization in the fall, claiming lack of medical necessity since services lapsed.
• Summer programming is also viewed as clinically valuable for observing peer interactions and community functioning that can’t be assessed during the school year.