Page 21, Exclusions and Limitations – provider cannot provide MCR, 23-hour, Crisis Stab or residential Crisis Stab to anyone receiving CPST.  This excludes CSBs who are regional HUBs and provide all of these services.  Will exclude individuals from necessary services to divert from hospitalization. Blocking access to needed services.  Please remove this requirement.

• Individuals may decline ACT, CSC, MST, FFT services or may not be appropriate for any of these EBPs as the EBPs do not capture the entire population served.  Earlier in the manual it permits serving individuals with co-occurring MH and SUD needs however they are not able to access ASAM services.  This exclusions creates a barrier to progress to addressing any SUD needs.  Please allow individuals to treat their SUD condition while also receiving this service.  Similarly, they should also be able to receive Clubhouse services as well.

Page 22, Exclusions and Service Limitations

Covered service components are limited to one hour week.  Behavioral theory indicates that individuals need repetition and practice to acquire skills.  This one-hour limit per week does not allow for skills practice, reinforcement, or repetition needed to help someone with SED or SMI learning a skill.  Please remove this and allow the provider to use discretion on how they will use the units approved by the MCO.