As a Provider/Director for Intensive In-Home Services, we too, share the same concerns that our colleagues have stated in regard to the proposed regulation changes to remove case management as a function of In-Home Services. This change would be a disservice to individuals and families in care. Delegating case management services to the CSBs would affect the timeliness of these individuals’ needs being met, effectiveness of treatment, rapport, and further place them at risk.  From our observation, it already appears that the CSBs are overwhelmed with their caseloads and they lack the flexibility needed to provide immediate care. Many of the families we serve are faced with an array of challenges that impede their ability to schedule and attend appointments, advocate for themselves, and access community resources. Assisting our clients with these complex case management needs are an integral part of Intensive In-Home Services and treatment planning. We would not like to see the response to families fractured by having two providers present what should be a seamless response.  .