Section: 3.1.2 Other Clinical Assessments to Support Measurement Based Care

• Are the assessments listed in this section optional?  What is the expectation behind the “strongly encouraged” wording in the first sentence?

Section: 3.2 Referral to Standalone EBPs

• Please provide clarification of justification for not allowing an individual to access both CPST and Clubhouse Model of Psychosocial Rehabilitation if both services are clinically indicated and appropriate.
• The requirement of referrals to the other services listed seems to limit individual/family choice, delay access to needed services, and be inappropriate in situations where one of the listed services is not available in the geographic area.
• If required to ensure the CANS Lifetime is not repeated if transferred to a provider agency who did not complete it, who “owns” or holds “accountability” for the CANS?  When does that ownership/accountability transfer?
• Who determines if the individual is not making appropriate progress within the authorization period to trigger the requirement of referral to an appropriate EBP? 
• What documentation of this referral is needed?
• What if the individual/family member declines such a referral?

Section: 3.3.2 Service Delivery specific to Adults

• The first sentence indicates all adult service agencies must meet the state requirements for training in Adult Mental Health Rehabilitative Supports and Services.  The next sentence indicates all professional types must complete….  Does this mean that all professional types providing CPST must meet the requirements or does this mean that all professional types within the agency providing CPST must meet the requirements?  Many agencies provide services outside of the CPST so clarification on the agency level expectations are needed.
• Please provide the justification for the requirement to include clinical best practice guidelines to the degree of specificity of diagnosis in policy.  This is a level of granularity not typically included in policy documents. 

Section: 3.3.3 Service Delivery-Transitional Age Youth

• If you are an adult only provider of CPST, serving only individuals over the age of 18, does the sentence requiring that providers complete all the adult and youth trainings indicated above apply?  If so, would that same requirement apply for adult providers who limit their services to only individuals over the age of 25?

Section: 3.4 Required Documentation

• Recommend switching to requiring proof of compliance with training requirements to be provided at audit.  This would avoid an increase in administrative burden and allow the provision of the most up-to-date compliance information versus limiting to just annual.