Updates and Clarification on Behavior Health Redesign

July 31, 2025

Based on additional research and conversations, we can offer the following about the Behavioral Health Redesign:

 

SURVEY

• The survey, while not required, is encouraged; they hope to glean information about staffing patterns and about numbers for training purposes.  While many of the questions are marked “required,”  there are also some that are not – if you have not had the time or sufficient information to give a thought out answer – leave it blank.  
• Please feel free to use the last question – an open field – to ask questions or raise concerns!

 

LETTER of INTENT

• This will be due in October and, hopefully, the draft regulations for Licensing will be out before then.
• It is “required” only to the extent that the Office of Licensing will prioritize for review those providers who filed the letter of intent; others may apply to be licensed, but it may be delayed.

 

STAFFING/PROGRAM DETAILS

• First – the only ones of the current services impacted are TDT, MHSS, IIH and PSR; all other services remain in their current configuration. 
• Second (and this is easy to miss) pay close attention to the titles on the slides from the webinar slide deck; if the slide is of the “Rate Study Assumptions” it should not be read as proposed staffing requirements.  For example – the Clubhouse model “regulations” will not include a requirements for a “Medical Director” – they will require an appropriate site and will expect the program to work toward those elements included on slide 33 and work toward accreditation.
• The overall expectation is that all providers of these services will adopt an EBP model of care which includes an appropriate level of clinical oversight and supervision by a licensed professional who is on staff full time. CANS has been selected as the assessment that will drive the transition to a Level of Need model for the state (a requirement for the 1115 SMI waiver) and MAP has been selected as the statewide framework for integrating a broad range of evidence based practices into the child serving system. However, there will continue to be robust discussion and planning related to timeline, expectations, and pathways to ensuring all providers are trained within a reasonable time frame. (Note the MAP is only applicable for youth, a similar tool will be developed for adults)

 

TRANSITION

• It seems to be clear that you can not “flip a switch” and transition from one array of services to another at midnight on June 30, 2026. 
• While the services listed above will no longer exist – ramping up for the new services may take a little longer.  As we know the “theory” of phasing in may be a good one; it is not clear yet what will be actually “billable” on July 1^st.  
• If this means that authorizations granted under the current billing codes will be honored past July 1^st, that will afford the providers at least time to submit new authorizations; and if this means that new authorizations can be done without all of the components of the new service fully in place, that will be even better.
• This may require that providers develop a provider-based or location-based implementation plan with timeframes for completion of specific components (eg., sufficient staff trained in the use of CANS or ANSA).  There is a lot of work yet to be done on this one.