I would like to take this opportunity to comment on the 20-hour cap on hours. This has the potential to have negative impacts on client care and I fear it sets a precedent to favor  administrative ease ahead of clinical judgment.

I strongly believe that clinically assessed medical necessity should determine the intensity of treatment, not a predetermined number of hours appplied to all clients. I am aware that this is not truly a cap on hours and that additional hours can be requested, however, that additional process of requesting often delays care to clients who need it most. 

I strongly urge DMAS to preserve individualized treatment planning based on medical necessity to ensure that client hours remain a clinical decision, not an adminstrative decision.