A summary of feedback from our members on this section follows:

Assessments, ISPs, and Reviews

• Lack of clarity on who can write assessments, ISPs, and quarterly reviews. Draft suggests LMHP-types may complete assessments with LMHP sign-off, but ISP and quarterly review authorship is vague.
• Requiring all team members to attend quarterly reviews is impractical, especially for home/community-based services.
• Confusion remains about whether multiple assessments (CANS plus additional tools) are required and who “owns” the CANS once completed.

Crisis Support Requirements

• Expectation for 24/7/365 crisis coverage by LMHP-level staff is unworkable given reimbursement rates and workforce shortages.
• CPST is not a crisis service, yet the redesign prohibits referral to crisis services (e.g., 988, Mobile Crisis Response), leaving clients at risk and creating liability for providers.
• Requiring in-person crisis response in rural areas is unrealistic; telehealth/phone support should be permitted.

Staffing and Workforce Limitations

• Restrictions on QMHP-T and BHT roles (e.g., cannot provide crisis support, RLST, or care coordination) reduce workforce flexibility and harm the pipeline of future QMHPs.
• LMHPs already face excessive workload demands (assessments, ISPs, quarterly reviews, sign-offs), making new requirements unsustainable.
• Agencies may not be able to recruit or compensate licensed staff to meet these obligations, especially given inadequate rates.

Service Delivery and Documentation Burden

• Requirements for trauma-informed CANS in-person only are unnecessary; telehealth has proven effective.
• Ambiguity about service delivery: minimum session lengths, caregiver-only sessions, and workplace supports need clarification.
• Care coordination billing rules (e.g., 15-minute increments) don’t reflect real-world practice where activities are often shorter.

Treatment Planning and Continuity

• ISPs must be developed with natural supports, reviewed every 90 days in-person, and updated if insufficient progress. But standards for what counts as “progress” (tool scores vs. clinical judgment) are unclear.
• Restricting crisis planning language risks leaving clients without access to appropriate supports post-discharge.
• If CANS identifies services unavailable in the community, the draft offers no guidance on next steps.