On behalf of the Virginia Association of Community Based Providers (VACBP), thank you for the opportunity to comment on proposed changes to MHSS and CI.  The VACBP supports the broadening of credentials for the provision of MHSS, however we are concerned about the impact of the proposed five-hour cap per day to the quality of services when they require more than five hours to provide.  There are circumstances regarding treatment of symptoms that occur during a service and there are services provided while waiting with a client for other services that cause the treatment time to exceed the proposed cap.  We ask that MHSS services be treated similarly to the proposed CI services in that any services beyond 5 hours (8 hours for CI) would be more closely scrutinized.  Allowing similar flexibility and oversight for both services would help to meet client needs while closely monitoring any potential over utilization.  With regard to CI requirements to re-register a person and perform SSPI and ISP updates every 7 days, we are concerned that these requirements take away valuable and needed treatment time and may result in more hospitalizations due to diminished effectiveness of the CI service.  We ask that you not implement a cap on MHSS and that you not implement the new administrative requirements for CI.