I wanted to offer some initial responses to the Draft policies for CPST - School. I do appreciate the efforts to increase use of evidence-based practices and to improve the quality of services for our clients! I can see that the intentions for the services are good and show a desire to serve our communities and improve mental health functioning. However, I do have some concerns with policies that I believe will have several unintended consequences.

• I can understand the reasoning for not having CPST - Community overlap with some of the EBPs that are also in the home/community setting. However, if CPST - School is denied due to the client qualifying for an EBP or different service, it seems like there will not be any other available services for the school setting specifically. MFT, FFT, CSC… it doesn’t seem like any of these would provide the level of support needed in the school setting, especially for Tier 2 clients. 

  • This would move the responsibility for treatment onto schools, FAPT teams, and other funding sources which would likely lead to increased out-of-school placement into alternative settings. In my local community specifically, alternative schools fill up very quickly. I have seen many clients forced into homebound instruction due to no alternative school placement being available. I think the referral requirement, specifically for CPST - School, could have a significant impact on highest needs clients who would lose access to needed education. I would ask that this requirement be reconsidered in view of the other services not be appropriate for the school setting.

• Requiring Clinical Supervisors to be part of face-to-face 90 day reviews for every client will pose a challenge with both time requirements and scheduling. In theory, they could be supervising 9 clinicians who could have up to 20 clients. That’s up to 180 clients they would need to personally be available to meet with over a 3 month period. While most staff will not be maxed out on caseloads to that degree, this requirement along with the extensive supervision requirements seems like too high of a demand for the amount of time needed in addition to requirements such as providing psychotherapy, reviewing and guiding staff through critical incidents, reviewing documentation every 30 days, crisis response, and more that they may be asked to do. Please consider altering this requirement for clinical supervisors to sign, but not necessarily be a part of, the 90 day reviews.

• Another related concern is the amount of administration and supervision required of LMHPs. I would like to offer caution about the difference between “capability” and “capacity.” An LMHP is likely capable of doing all of these activities (supervision, paperwork review, attending ISP review meetings, weekly team meetings, etc.) at a high level, but when all of those things are one person’s responsibility, the quality of the services are more likely to go down due to diminished capacity.
  • I would request that QMHP and LMHP-eligible staff’s supervision requirements be decreased AND that the list of who can provide supervision be expanded. The board of counseling has approved for QMHPs with experience and training to act as supervisors - this could actually improve quality of services as experienced QMHPs can speak to the service being provided and would have greater capacity for discussing client cases than a LMHP with numerous other administrative tasks.
  • Other ideas such as allowing supervisory QMHPs to sign paperwork for QMHP-level services and not requiring Clinical supervisors to be present for face-to-face ISP reviews every 90 days would decrease the administrative requirements while still allowing for LMHP oversight through occasional supervision and some document review. Please consider how the amount of work required impacts service quality as much if not more than the capability or professional level of a staff.

• I have some concerns with the 24/7 crisis response for school-based clients. A school-based service should be predominantly responsible for the school setting (which is also acknowledged in the draft in section 5.2, point 9). Occasional home interventions, such as with parents/guardians, may be appropriate (as noted in the draft policies), but generally, clients should be receiving the support in the school environment. If a client is experiencing crises in the community/home setting, there needs to be services provided specifically in that setting and referrals for other services such as CPST-Community. Requiring school-based staff to be available 24/7 significantly alters the purpose of this service, will impact availability of the workforce, and will create additional challenges with staffing, particularly for rural agencies.

  • For example, Staff who drive 15 minutes to a school may be asked to drive 30+ minutes to a client’s house in the middle of the night, something school staff have not previously been asked to do and something that does not appear to be built into rates. Please reconsider this component and think of how this need could be addressed in a different way.

• I would like to request allowing QMHP-Ts to provide Care Coordination since they can be directly involved in the Restorative Life Skills Training. Collaboration with other providers can and should be practiced by trainees.

• I would also like to request that Restorative Life Skills Practice be able to be done in group settings. Practicing skills with a clinician is great! But in the school setting specifically, practicing with peers is a valuable opportunity, especially when that practice is facilitated by a trained adult. In my experiences, peer conflict is one of the most common reasons that children are referred to services by schools. Clients need a safe place to practice the skills they are learning during training with peers, not just their MH providers.

• I can foresee potential challenges with guardian participation requirements for the school setting such as guardians who work, are unable to join, may not have consistent Wi-Fi access or transportation, may not trust mental health providers, etc. I would request for there to be more specific guidelines on what “participation” looks like. 

  • Additionally, can there be exceptions made for guardians who are unable or unwilling to participate in services? While I highly value and would prefer guardian participation, and I agree that it does improve outcomes, it can take several weeks or months to build rapport with guardians who have had poor experiences with mental health services or are less trusting. This requirement will prevent clients with less involved guardians from accessing needed services. These clients are often those with the highest needs and would be significantly impacted by the loss of service access due to actions of their guardian, something which is beyond the client’s control.

Thank you for your time and consideration on these points and the feedback from other providers!