While the intent of these new requirements/changes is understandable and laudable my experience with working at a CMHA is that they will only take away time that clinicians/providers can actually spend working with clients. As the clinical supervisor of a CMHA I watch providers constantly have to contort their otherwise-helpful therapeutic approaches into much-less-useful approaches just so that the agency and provider can pass its next audit. Every time an agency/provider has to worry about passing a new audit comprised of well-intended minutiae the client suffers from the shift of therapeutic attention, the agency suffers by having to spend resources on passing audits rather than helping clients, and the providers suffer from more nagging fears and doubts that they are not dotting an i or crossing a t somewhere.
So much time is already lost on fulfilling mandated requirements. Please don't add to this. Our clients deserve better.
Thank you for the opportunity to respond.
WA
This is comment on Proposed Rule
Medicare Program: Conditions of Participation for Community Mental Health Centers
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