• Requirements to list “materials used” in sessions are vague and add unnecessary complexity.

• Mandatory LMHP co-signatures further slow service delivery- and adds to the long list of non-reimbursable activities for a licensed staff.  

• Team meetings weekly are also not very realistic- to include licensed supervisor, team members, and to be able to mesh their schedules weekly, and how many team meetings would that supervisor be able to conduct in addition to providing supervisions.  While group supervision can be used, the idea that all of the team members are in the same group supervisions (limit to how many are in a group) for every case is unrealistic when staff are going to need more clients due to less hours being approved
• During the ISP reviews with the family and team members will everyone get to bill for that or will just one provider- which will then fall on admin duties
• Case coordination over the phone due to the only means that a provider from another agency is available is not going to be reimbursable?  If so that's more admin type duties without reimbursement for these employees
• Lower hours being able to be provided for the clients will require a larger caseload for the staff, more documentation for the licensed provider doing the isps, therefore increased burnout of staff and supervisors
• Requiring a licensed staff senior to be available for crisis calls without any ability to reimburse as well at that level is also going to strain the already busy licensed staff.  

While concepts of this redesign sound great, the implementation sounds like more licensed required activities, less QMHP required activities- where are all these staff going to come from?  In the training DMAS said this will allow more flexibility but in fact its increasing in rigidity and even going against what DMAS has identified that can occur with supervisors (why change the ability to supervise to LMHP-R/S or QMHP senior staff if that wouldn't be allowable with this service?