In general, the draft manual adds heavy administrative (supervision and use of LMHPs) and heavy training burdens for the program and agency, excessive supervisory requirements; Very long and complex regulations – recommend simplifying and shortening the manual; Increased use of LMHPs and Clinical Director increases cost (that are not included in the rate or the assumptions for the rate) to provide services.  Requiring a team-based approach to service provision increases costs significantly.  Cost to provide CPST far outweigh the cost reporting survey that was provided to DMAS and Mercer.