Requiring involvement of a Licensed Clinical Supervisor in signing the ISP, completing quarterly reviews, updating the ISP, and consulting about the use of telemedicine or group, is a level of supervisor that is not needed for these activities.  An LMHP, who is not necessarily the Clinical Supervisor, should be sufficient.

 

Yes, crisis support is best provided by the team that serves the individual during business hours. However, expecting there to be 24/7/365 coverage by the CPST Team for providers such as CSBs who are already mandated to provide such crisis coverage is an undue burden and decreases the feasibility of providing CPST service. Providers should be able to use any 24/7/365 crisis personnel already employed or contracted by them.  It is also suggested this be removed from 8.2.b.i. Exclusions and Limitations.