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

Monthly Unit Cap Concerns

• The 504-unit monthly cap for non-licensed staff is viewed as too restrictive and will limit service delivery capacity, especially in programs with high client needs.
• This cap could shift excessive workload to LMHPs, increasing their caseload burden and reducing supervision quality.

Tracking and Enforcement Challenges

• It is unclear how the 504-unit cap will be monitored or enforced, particularly since staff often work for multiple agencies.
• Agencies have no mechanism to know when an employee’s total units across employers exceed the cap, creating compliance and audit risks.

Implementation and Readiness Issues

• Providers cannot build electronic health record (EHR) templates or prepare billing processes until DMAS finalizes provider type/specialty codes and DBHDS completes the service definition.
• The lack of finalized guidance delays operational readiness; providers request billing guides and test-claim scenarios to ensure correct implementation.