Page 20 7.6, Continued Stay Criteria – Some individuals take time to engage and may see little progress in 90 days.  This time frame does not have regard for the persistent and chronic nature of the condition.  Working with the MCO to develop an alternative ISP after 90 days is heavy administrative burden.  Please remove this requirement or consider a longer time frame such as 12 months.

Page 20, 7.7  Discharge Criteria – The expectation that individuals will have completed this service in 4 – 12 months lacks regard for the episodic, persistent and chronic nature of serious mental illness or serious emotional disturbance that have SDOHs negatively impacting functioning and level of progress.  Please recognize that individuals may need 18-24 months to develop some skills or complete goals depending on the severity of their illness.