As a current provider of PSR and MHSS services, we have several concerns about the proposed service definition.  

QMHP supervisors – DHP just created a pathway for QMHP-T’s to be supervised by experienced QMHP’s. Because agencies worked together for Redesign, we are wondering why QMHP’s are not allowed to supervise under CPST.  

CPST and Clubhouse – The regs read as though a Medicaid member may not participate in both CPST and Clubhouse. These are two very different programs that complement each other well. We would ask that members be able to participate in both. The regs also read that there is no member choice (3.2). If that is not correct, the wording could be clearer. 

Caseload Cap – Controlling the number of billable services per employee makes sense. Controlling the caseload does not. A cap doesn’t allow members who need a few weeks to truly engage in the service and it doesn’t allow to titrate down. The cap means all 20 members need to be meeting often for companies to pay salaries. If someone is hospitalized for two weeks, which is common, then we would have to take them off a caseload and then add them back in when discharged so staff could see other members. Please consider eliminating this.  

In person Supervision – The industry standard is face to face supervision, not in person. With the increased supervisory requirements and the inability to utilize QMHP’s as supervisors, please consider allowing virtual face to face. 

4-12 Months: CPST, especially for adults, is going to be more successful with a little more time. 18-24 months is what we are seeing for members to show notable improvement. Having 4-12 months, even as a recommended timeframe, is going to lead to unsuccessful services. 

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