We respectfully request that the Department clarify ambiguous language, reconcile conflicts with existing licensing requirements, reduce unnecessary administrative burden, preserve provider flexibility, and ensure that implementation supports rather than impedes timely access to high-quality, person-centered behavioral health services.

We encourage continued collaboration with providers prior to finalizing the manual so that implementation is clinically feasible, operationally sustainable, and aligned with the shared goal of improving outcomes for individuals receiving CPST services.

Suggested Alternatives

• Permit another qualified LMHP to fulfill Clinical Director responsibilities during absences.
• Align CANS requirements with existing DBHDS licensing standards or formally replace the CNA if appropriate.
• Provide operational definitions for all subjective terminology.
• Reduce documentation by incorporating required elements into existing ISP and progress note formats rather than creating separate documentation.
• Allow providers to document EBP consideration rather than requiring referrals in every applicable circumstance.
• Preserve individual choice by explicitly allowing individuals to decline recommended services while remaining eligible for medically necessary treatment.
• Clarify that existing CSB Emergency Services may satisfy 24/7 on-call requirements.
• Allow qualified mental health case managers to continue performing care coordination without duplication.
• Accept provider learning management systems and audit documentation instead of requiring duplicate reporting in multiple databases.
• Reevaluate supervision, caseload, and credentialing requirements to ensure they are achievable given current workforce shortages.
• Clarify the role of MCOs so that provider clinical judgment and person-centered treatment planning remain the primary basis for service authorization.
• Publish implementation guidance, timelines, assessment tools, and training information well in advance of compliance dates.