WA

Document ID: CMS-2011-0123-0008
Document Type: Public Submission
Agency: Centers For Medicare & Medicaid Services
Received Date: July 07 2011, at 12:00 AM Eastern Daylight Time
Date Posted: July 21 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 17 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 16 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ebc517
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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.

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