With the massive reduction in TDT services since the MCO’s replaced Magellan for service authorization, I’ve been hopeful for a better redesign for a long time, but upon reading the proposed changes and watching the PowerPoint presentation, this seems like it will be even worse than our current system. TDT services once created a safety buffer for our schools and children’s mental health services. When I see school related tragedies in the news now, I wonder if they could have been prevented if the state hadn’t lost so many TDT providers in the last 6 years. COVID was an excuse to explain the reduction in services, but it had already begun with the MCO’s long before COVID became a problem. We had already seen a large cut in providers in our area before COVID even started and now we have no TDT providers in our area. A service that once flourished and was considered by many to be the most important program in the community no longer exists in the area where I live due to the difficulty of getting approvals and low reimbursement rates. With the redesign I see many new challenges that will likely save the state more money and continue to reduce the effectiveness and availability of services. First, I don’t agree with using the CANS for the assessment. As someone who has worked with many providers through the years and has seen the variance in ratings with the CANS, this tool is completely unreliable, despite how it may be presented. Second, requiring LMHP’s to write treatment plans is another difficult addition in a state where we already have a shortage of LMHP’s. QMHP staff are more than capable of writing a treatment plan. This would be a waste of our LMHP’s time. The new rates being below average of what other states pay is also disappointing, especially in a state with a higher minimum wage than thirty other states. How are we supposed to pay staff a competitive salary when we have one of the lowest billing rates of states but have one of the highest minimum wage rates. The short authorization periods are not realistic for kids who are dealing with generational trauma and/or have severe mental health concerns. Upon reading this, I initially thought that this is going to be even harder to get approvals, more waste of time doing paperwork, shorter treatment windows, less effective treatment, more difficulty in having a program that can break even financially, and less help for our youth dealing with mental health needs. Lastly, why is this comment period so short?