Section 5.  Required Service Components

• Max of two hours provided in licensed location per week. Does this requirement apply to CPST services provided in-home when the individual resides in a licensed location?

Section: 5.2 Treatment Planning

• Requirement for ISP to be signed by all team members is overly restricted and not required in most, if not, any other service.
• Required participation by all members face to face/in person is further over-restriction that exceeds the requirements in most, if not, any other service.

5.5 Care Coordination

• The updated draft adds an entirely new list of required care coordination activities which may not have been included in the rate study as they were not included in the original policy.  This adds additional time, costs, and burden which is not supported by the rates assigned for this service.