Page 12, 5.1  Required Service Components - Assessment:  CANS Lifetime cannot be found anywhere.  Is there an existing tool?  What happens to the CNA as CSBs use this for Same Day Access for all BH services including SUD services. 

• LMHP must sign off on assessments completed my LMHP-type – are LMHP and LMHP-types not synonymous?  The workforce doesn’t have enough fully licensed staff to sign off on LMHP-types.
• ISP must be “overseen” and authorized by LMHP – administrative burden and additional cost.  Please remove the requirement

Page 13, Crisis Support – If an agency has emergency services,  recommend allowing the agency to use emergency services.  The requirement of availability 24/7/365 significantly increases costs. It is recommended that individuals have access to the MCR service.  Many times, an individual calls 988 without provider knowing or experiences a crisis in the community without provider knowing.  MCR should be able to respond so that there are no barriers to access to crisis care.

Page 14, Restorative Life Skills – only specific mention of employment or “instruction”.  Does this include ADLs and IADLs, coping skills, symptom management, independent living, emotional regulation, conflict resolution, delaying and managing impulses, building healthy relationships, social and pro-social skills development or rehab?  QMHP-Ts are already hired in organizations and have been to do most things that QMHPs can do…this will cause a workforce issue.  Recommend that QMHP-Ts be allowed to do skills restoration.