Thank you for reviewing and taking into consideration the comments below, related to the recently released draft policies for CPST-School Setting.

Screening Tool/Assessment & Training Requirements:

• The “CANS Lifetime” has not been publicly released and seemingly not tested for validity and cross-rater reliability, but yet continues to be cited as the mandated screening tool for CPST services.  To date, there is no screening tool and there are no training plans for CANS Lifetime.    
• Planned MAP training is limited in capacity; as such, CPST service providers will have to bear the financial burden for independently training staff.
• All CPST youth providers are required to complete a new "foundational, state-wide Youth Mental Health Rehabilitative Supports & Services training". Like for CANS Lifetime, a training plan is also needed for this component and preferably will include timeline, location(s), and entity(ies) responsible for/available to provide this training.
• Mandates to annually submit documentation to CEP-VA which substantiates staff-mandated training, puts additional administrative burden on CPST service providers.     

Service Delivery & Coordination Requirements:

• The requirement for youth to be referred to and offered a “Standalone EBP” prior to CPST authorization will significantly delay treatment and cause substantial frustration and confusion for families.
•  Excluding youth from CPST Services-School Setting who meet criteria and/or are receiving MST or FFT services is not reflective of person-centered, individualized treatment planning or service delivery.  MST & FFT are prescriptive EBPs that do not provide daily services & supports within a school setting.  
• Regarding the exclusion of crisis response services delivered under the state-wide “Right Help, Right Now” model and within the regional crisis continuum for a youth receiving CPST services, this prohibition is not reflective of person-centered, individualized treatment planning or service delivery either.  With those services delivered under the crisis continuum, it is the expectation for service delivery to be immediate, clinically responsive to the highest acuity level of need, and provided regardless of other existing services.  It is simply not feasible (nor clinically appropriate) for crisis continuum service providers to ‘screen out’ those youth and families currently receiving CPST services.  Furthermore, it is duplicative and fiscally irresponsible to replicate a second system of care with 24/7/365 crisis response.
• Consideration should be given for QMHPs also being permitted to devise/write ISPs, under the review of the LMHP/LMHP-E Type.          
• The requirement for caregivers to receive 30 minutes or greater of CPST services per week does not take into consideration valid time constraints for a family (caring for other siblings, parent employment, transportation barriers).  It also does not take into account older adolescents who are permitted to receive treatment services without parental consent, according to VA Code.         

Supervision & Oversight Requirements:

• Under the proposed CPST Team structure, QMHP staff are categorized as “paraprofessionals”; this categorization diminishes the knowledge/education, skills, and abilities of many experienced, highly qualified professionals who have four-year, human services-related degrees and have been providing within scope-of-practice and clinically appropriate interventions to youth & families, for years and in some cases even decades.  Differentiation between QMHP staff and BHT staff should be taken into consideration with regard to not only supervision requirements, but also in reimbursement rates for the various Tier-Level “Teams”.  Of particular note, there are already set standards for training and supervision of QMHP-Ts, as established by the Board of Counseling.    
• The restriction of an LMHP Clinical Supervisor supervising only nine (9) CPST employees is too limiting, from a staffing perspective and in the midst of the behavioral healthcare workforce shortage. 
• Likewise, the restriction of an LMHP Clinical Supervisor only being permitted nine (9) CPST employees in a Group Supervision setting is too limiting, from a staffing perspective and in the midst of the behavioral healthcare workforce shortage. 
• Clarification is needed regarding the definition of and expectations for the “Clinical Director”, and the required supervision of “Licensed” LMHPs by the CPST agency’s Clinical Director.  If an agency, regardless of size, only has one named “Clinical Director”, is that Clinical Director required to provide the indicated supervision to “Licensed” LMHPs?   
• The requirement for senior, experienced LMHPs to be available to provide 24/7/365 consultation to employees is a sizable financial and staffing burden for CPST providers, as these senior, experienced LMHPs will have to be paid accordingly and at a differential rate.   
• For those LMHP-E Types in Clinical Supervision for Licensure outside of the CPST agency, it will create administrative burden to negotiate and collect “official documentation of supervision sessions” from outside-of-agency Clinical Supervisors.  This requirement could also greatly restrict or even eliminate the LMHP-E’s choice of Clinical Supervisor.        

Accreditation & Implementation Timeline:

• Accreditation is a weighty administrative and financial burden on the CPST agency.  In reaching out to a number of the recommended accreditation agencies , it was reported that they do not currently have enough surveyors/reviewers and already have a sizable list equating to over a one (1) year wait to begin the process.     
• The allowable time is inadequate for providers to re-configure and build out electronic health records (EHR) for entirely new 1) services/service codes and 2) billing structures, neither of which have been clearly/formally defined or solidified.
• The state-wide capacity and allowable time are inadequate, for training related to CANS Lifetime and MAP, both cited as mandates for CPST authorization and service delivery.

In closing, the most concerning potential consequence of rushing this implementation will be the detrimental impact it has on Virginia’s young people and their families who are currently receiving these “Legacy” services.  Most providers embrace EBPs and the desire to achieve better clinical outcomes for those they serve … but if not executed in a planful manner, the effects could be particularly devastating to those most in need of our support.  Thank you again for taking your time and giving your attention to review these comments.

Trân trọng gửi,

Paulette Skapars