Overall, HopeLink appreciates the level of detail and needs considered by this publication and has few concerns about the stated plans. 

4.2 Assignment of Care 

• REQUEST: It is requested that providers who receive licenses to offer the new services be provided with the contact information of the MCO care coordinator for all of its members, by each MCO, when this step occurs. 

5.3 Specialized Conversion Crosswalk 

• The idea that the specified active services (TDT, PSR, DBHDS-funded CSC) do not have a clear 1:1 transition and require a different process than the standard conversions is understood. However, some details are missing from this section that explain the process. The section states, “The CCMCO or Acentra identifies the appropriate service, in collaboration with the member an creates the authorization.” This lacks clarity as to what goes into determining the appropriate service. The following is requested. 

• • REQUEST: Please explain/clarify how current PSR members will be determined to transition to Clubhouse versus CPST. Will this be based on the provider’s transition (for example, if a current PSR provider plans to offer Clubhouse, will all of the current PSR members be authorized to Clubhouse- and likewise, if a current PSR provider plans to offer CPST but NOT Clubhouse, will its current PSR members be authorized to CPST)? 

• REQUEST: Please clarify how MCOs will be notified that a member is currently receiving DBHDS-funded CSC. 

5.5 Authorization Transition Principles 

• Given that MHSS is only authorized for 3-month periods currently, it is expected that nearly all MHSS-to-CPST converted auths will end in the period from July 1 to September 30, 2027. This section states that a CANS Lifetime assessment be completed “by the end of the transitioned authorization.” This requirement will create a bottleneck of a concentrated number of assessments due within a 3-month time period not only for 2027, but for each subsequent year that these individuals remain in any Medicaid-funded mental health service, since the CANS-Lifetime cannot be completed early and still billed at the assessment rate. It is suggested that the impact on workflow and availability of licensed providers to complete assessments during a concentrated period, instead of spread out through the year, be considered. 

• • REQUEST: please consider amending this requirement to require that the CANS Lifetime be completed at the time the individual’s annual Comprehensive Needs Assessment would normally be due, and consider determining continued service authorization at the current LON or adjusted LON on other relevant information, such as quarterly review of treatment plan and service utilization and engagement.