Complex Terminology: The use of numerous specialized terms (e.g., LMHP-type, CANS Lifetime, CPST) may be confusing for providers unfamiliar with the updated language. This could necessitate additional training and administrative support to ensure proper understanding and implementation.

• Concerns with the CANS Assessment Tool:
• Lack of Standardization: The CANS tool exists in multiple versions, often customized by local agencies. This variability undermines consistency and comparability across providers and regions.
• Limited Validity and Reliability: There is a scarcity of peer-reviewed research confirming the tool’s validity and reliability. A 2024 study examining its internal structure revealed inconsistent findings, raising concerns about its psychometric soundness.
• Changing Rating Scales: The evolution from severity-based to action-based rating scales complicates longitudinal comparisons and may obscure clinical progress.
• Ambiguity in Outcome Measurement: CANS ratings reflect a child’s functioning without treatment, not their current status with interventions in place. This can result in persistently high scores even when a child is improving, making it difficult to demonstrate treatment effectiveness.

Section 2: Service Definition / Critical Features

• Mandatory Family/Caregiver Involvement: Requiring caregiver participation may pose challenges for families facing barriers such as limited availability, transportation issues, or engagement difficulties.

Section 2.2: CPST Teams

• Rigid Team Composition: The mandated tiered structure requiring specific combinations of licensed and paraprofessional staff may be difficult to maintain, especially amid workforce shortages.
• Supervision Demands: Requiring LMHP Clinical Supervisors to oversee all licensed service components significantly increases their workload and will likely impact service delivery in regard to timeliness of start/delays in treatment.

Section 3: Required Evidence-Based Practices

• Yêu cầu đào tạo: Mandating MAP and other evidence-based trainings for all staff could impose significant time and financial burden on agencies.
• Referral Protocols: Requiring providers to assess and refer individuals to standalone EBPs prior to CPST authorization—even when such services are unavailable within the agency—adds complexity and will delay care.

Section 3.3: Service Delivery Requirements

• Dual Training for Transition-Age Youth Providers: Agencies serving youth aged 16–25 must complete both youth and adult training modules, increasing the training burden.
• Mandatory Statewide Training: Requiring all staff to complete foundational modules may be difficult to coordinate, track, and execute, particularly for part-time or newly hired employees and within the implementation target dates.

Section 4: Service Oversight and Supervision

• Supervision Ratios: Limiting LMHP Clinical Supervisors to overseeing only nine staff will hinder staffing flexibility and necessitate additional hires, resulting in limited access to treatment .
• In-Person Supervision Mandate: Requiring at least 50% of supervision to be conducted in person presents logistical challenges, especially for agencies with rural, remote,  or part-time staff.
• 24/7 LMHP Availability: Mandating continuous LMHP availability for consultation may be unsustainable without substantial staffing resources.