Although the total units per six month period increased to allow 10 units per week, there is an issue with the maximum amount of units billed per day being capped at 2. This restriction is especially an issue when it comes to servicing individuals both in their home and in the community who live in rural and remote areas. Often individuals do not have access to providers who 1) are located in the area because it is expansive and there is no public transportation option and/or 2)  accept Medicaid insurance in the area. While 5 hour sessions are rare, extenuating circumstances do arise to address immediate medical and psychiatric needs. Some individuals are in need of training during emergency room visits and multiple appointments with providers in the same day. 

Please reconsider capping the daily unit limit to 2 and allow 5 hour sessions if training services provided are justified. 

In addition, I think it is important for MHSS to focus on basic life skills instead of activities of daily living considering that much of what is defined as ADLs requires specialized training outside of the scope of being a mental health professional. Basic ADLs: eating, bathing, dressing, toileting, transferring (walking) and continence. While some basic life skills overlap with ADLs, both concepts are different and widely subjective. Please provide a breakdown of what exactly constitutes as ADLs cited in the changes so that there is a clear centralized base for all providers to work from.