A summary of feedback provided by our members on this section follows:

Assessment and Authorization Burden

• The draft requires CANS, full assessment, ISP, and SAR all completed and submitted for pre-service approval within one business day.
• This is seen as impractical and unworkable, especially for agencies serving high volumes or individuals in crisis who need more time to engage.
• The manual references an “initial assessment” in addition to CANS but doesn’t define it, raising duplication concerns.
• Confusion about who submits authorization if the agency completing the CANS is different from the one providing services.

Service Duration and Unit Caps

• Services limited to 4–12 months, raising concerns for consumers with chronic or lifelong needs. Agencies need clarity on extensions or long-term options.
• Tier caps are too low: Tier 1 = 32 units/month (~8 hrs); Tier 2 = 112 units/month (~28 hrs)
• Providers ask: Are exceptions allowed if more hours are clinically necessary? What happens if caps are hit during an emergency—are agencies expected to refuse service?
• Concern that reimbursement rates may vary by staff type (LMHP, QMHP, BHT), but rates are not specified.

Appeals and Service Reductions

• If MCOs reduce services, agencies must update ISPs, but it’s unclear whether appeals will be allowed and what evidence would be required.