I am opposed to this rule-making petition on several grounds; First,many of the issues of expressed concern are already covered by record-keeping requirements involving intake and discharge summaries; Second, formal testing is an added expense for families who are already struggling to afford copayments, coinsurance, and deductible payments; Third, such evaluations as proposed must be cleared by insurance carriers prior to being initiated, often slowing the providers' ability to deliver services due to the authorization process necessary for approval.