The proposed changes to the DBHDS regulation are welcomed, given the Department’s attempt to align the requirements put forth by DMAS and DBHDS governing licensed behavioral healthcare Providers. However, the proposed changes should ensure its additions will not contradict the current operations of Case Management/Support Coordination in the completion of related tasks. More specifically, this updated section of regulation [12VAC35-105-675], similar to the original, does not identify whether CM/SC staff is included in the definition of Provider. Clarification of this might require extension of the proposed quarterly submission and filing timelines to accommodate CM/SC responsibilities of acquiring collateral documents from other providers, appraisal and incorporating into quarterly review documentation. A blanket 15-days for completion and submission into the medical record for all Providers is not sufficient in this respect.