A summary of those issue identified as top concerns by our members follows:

Workforce and LMHP Over-Reliance

• The draft places an unsustainable burden on LMHPs—requiring 24/7 on-call availability, strict supervision ratios, in-person supervision mandates, and shifting licensed staff into paperwork and oversight rather than clinical care.
• Combined with inadequate rates, this will worsen workforce shortages, drive up costs through salary competition, and limit provider participation—especially in small and rural agencies.
• LMHP supervision standards must be feasible, flexible, and paired with rate structures that make recruitment/retention possible.

Unrealistic Service Design and Hour/Unit Caps

• Caps on weekly billable hours (e.g., 31.5 hours for non-licensed staff) and narrow service tiers (e.g., 1–1.5 hours per week at Tier 1) make it impossible to deliver quality care, especially when travel, documentation, and client needs are factored in.
• Prohibitions on concurrent authorizations (e.g., Clubhouse/CPST) and categorical exclusions if clients are eligible for another service artificially restrict access.
• We need clear, fixed service hour allocations (not ranges subject to MCO discretion) and oppose limits that undermine continuity of care or force service gaps.

Unfunded Administrative and Compliance Burden

• Providers face steep costs for mandatory trainings, accreditation, assessments, ISPs, SARs, and extensive documentation—with no offsetting funding.
• Front-loading assessments before authorization risks wasted work on treatment plans that may be denied.
• These requirements pull resources away from direct care and further strain already thin margins.
• We need phased implementation, funding support for compliance, and streamlined approval processes that don’t waste provider capacity.