Commenter: Zewditu Tadesse, health Connect America
Questions/Comments
In person supervision requirements- At least ½ of supervision hours received must be in person. This leads to scheduling constraints and increase costs due to travel burden for staff who are primarily out in the field providing services- can this be virtual?
LMHPs will have to serve clients in person at least once every 90 days- recruiting and retaining licensed staff is already a challenge state-wide. This will increase barriers to which areas we can offer services in and potentially disrupt services for clients during periods of staff turnover.
24 hour in Person Crisis Support- seems like a large burden on staff for a non-crisis or service line- rates do not support this level of care.
Recommended duration of services is 4-12 months- concern that is not long enough to support the high acuity type of clients that would be served based on admission criteria.
The CANS Lifetime assessment has not been provided for Agencies to review and would be the primary assessment tool to determine the appropriate LOC.
Individuals must be referred to and their needs assessed for any clinically appropriate standalone EBPs of which they may meet admission criteria, prior to the authorization of CPST services, regardless of whether the agency completing the CANS Lifetime offers the EBP. How would our staff know the criteria for every other EBP that we do not offer. This is an additional burden for staff to be expected to know the criteria for all other EBP and take on the lift of referring clients we cannot serve rather than providing them with an alternative service we can provide or other agency info.
Training- quite a few external trainings that would now be required- will the department be offering these for free or at the cost of providers?
