Southside Behavioral Health (SBH) appreciates the opportunity to comment on the proposed CANS Lifetime assessment policy. As a rural Community Services Board, we are concerned about the staffing, technology, and funding needed to implement these requirements while maintaining timely access to care. We request clarification and practical implementation support in the following areas.

1. Training availability, cost, and implementation time

SBH needs sufficient time to plan for training, arrange staff coverage, and complete certification before the requirements take effect. Please clarify:

• When initial training and certification will become available.
• The cost of initial training, certification, and annual recertification.
• Which staff must be certified, including assessors, supervisors, and clinicians who review or sign assessment components.
• Whether DMAS will fund training or provide it at no cost to agencies.
• How much time agencies will have to train staff after the final policy and training resources are released.

Requested action: Publish a coordinated training and implementation schedule, including costs and certification requirements. Allow a reasonable preparation period after final guidance and training become available.

2. Identifying existing assessments and coordinating with MCOs

The expectation that the CANS follows the individual depends on providers being able to determine whether an assessment already exists and obtain the current version. Communication between CSBs and MCOs can be difficult, and identifying the appropriate care coordinator or contact often requires substantial staff time.

Please clarify how an agency will:

• Determine whether another provider has completed a CANS.
• Obtain the current assessment, including before a shared electronic system is available.
• Identify the lead provider responsible for updates and reassessments.
• Address situations in which the existing assessment cannot be located or obtained promptly.
• Meet assessment and authorization deadlines when another provider or MCO has not responded.

Requested action: Establish a consistent process for locating and sharing assessments. Provide a regularly updated directory of direct MCO and fee-for-service contacts, with an escalation process when providers cannot obtain a response. Delays outside the agency’s control should not interrupt needed services.

3. Electronic documentation and EHR integration

The electronic documentation requirements are unclear. In particular, agencies need a clear definition of a “DMAS-approved electronic documentation system.” It is difficult to plan staffing, workflows, vendor changes, and costs without knowing whether this means an agency’s existing EHR, a separate state platform, or both.

Please clarify:

• Which systems qualify and whether an agency’s existing EHR must undergo an approval process.
• Whether agencies may build the required assessment into their existing EHR rather than reproduce a separate template.
• Whether information must also be entered into a separate DMAS system.
• How assessments will transfer between EHRs, the state system, MCOs, and other providers.
• What consent, access, security, and electronic signature requirements will apply.
• What process agencies should use until the required electronic system is operational.

Requested action: Design the process to support one-time documentation and electronic sharing, with minimal duplicate entry. Release final technical specifications early enough for EHR vendors and agencies to build, test, and implement the necessary changes. Identify any associated costs and available funding.

4. Quality assurance requirements and inter-rater reliability monitoring

The proposed quality assurance requirements would create additional, unfunded responsibilities for SBH’s small Quality and Compliance Department. These duties would require staff time that is already committed to existing licensing, payer, audit, and agency oversight requirements.

The requirement for regular inter-rater reliability monitoring does not clearly explain the expected method or frequency. Please specify:

• How often monitoring must occur and how many assessments or staff must be included.
• Who is qualified to conduct the review.
• Whether monitoring may be completed through case vignettes, joint scoring, observation, or review of existing assessment information.
• What scoring standard is required and what corrective action is expected when raters disagree.
• What documentation agencies must retain to demonstrate compliance.
• Whether annual certification or recertification can satisfy any portion of this requirement.

SBH is particularly concerned about any expectation that an individual complete the assessment twice solely to measure staff reliability. These assessments require substantial time and participation. Repeating the interview could create an unnecessary burden for individuals and families, particularly those experiencing significant symptoms or difficulty remaining engaged.

Requested action: Provide a standardized, proportionate monitoring process that does not require duplicate client interviews. Supply sample tools, clear scoring standards, and technical assistance. Allow agencies flexibility to incorporate monitoring into existing quality assurance processes and identify funding to support the additional workload.

SBH requests that these issues be resolved before implementation, with sufficient time and resources for agencies to prepare. Clear requirements, reliable information sharing, and practical oversight methods will help agencies implement the assessment consistently while preserving staff capacity and access to services.