Thank you for the opportunity to provide comments regarding the Draft regulations.
Concerns:
The new rate will reduce billing from $89.97(max of 3 units) to $72.41. The decrease in rates will increase the CSB financial burden and may require many PSR programs to close.
Psychoeducational groups will no longer be approved. Many enjoy and benefit from the Psychoeducational groups Please consider continuing the groups.
Staff will no longer be able to have offices with the CI model. How will staff complete the necessary documentation and required trainings?
The new regulations are requiring evenings, weekends, and 3 cultural holidays. This will create a burden for an already staffing shortage and may lead to burnout.
Will the CANs Lifetime assessment replace the CNA? Will a CNA still be required for other services? Two separate assessment will be a burden, waste of resources, and increase staff burnout.
Why does an LMHP have to oversee the ISP? This places additional work on an already workforce shortage of LMHPs with the BH system. Please reconsider having QMHP oversee the ISP.
Major concerns with a huge focus on employment and education. Focus should be more on maintenance, stability, and staying within their community. Workforce is already a challenge in rural areas for people without an SMI diagnosis. This would be a huge challenge in many rural areas.
Major concern with PSR staff responding to crisis situations. Mobile Crisis teams and crisis stabilization are trained for crisis situations. Having the PSR staff respond will again increase burnout and create vacancies.
Having LMHP review documentation of non-licensed staff every 30 days is an administrative burden on an already workforce shortage of LMHPs. Please consider changing.
Any observation without an intervention is not a "billable activity". Would this mean that PSR cannot bill for an individual that attends but does not interact? PSR is sometimes the only safe, non judgmental space for some individuals. Please consider changing.
