While the intent of CPST is presented with an intent go expand access to mental health services, CPST presents significant financial and operational challenges for mental health agencies. The service model is not cost-effective, lacks scalability, and poses threats to both revenue stability and workforce sustainability.

CPST requires greater amounts of licensed or licensed-eligible staff than the legacy services it is designed to replace. CPST will increase the activities required by those staff and decrease the abilities of QMHP level staff to provide adequate support and intervention due to severe limits on service units provided. With recent changes to QMHP training and supervision requirements, how is this helpful in reducing the burden placed on LMHP type staff and supporting the appropriate utilization of QMHP staff?

Proposed reimbursement rates do not align with actual costs including salaries, training, travel, and supervision. The margins are slim to negative, making sustainability unrealistic. CPST is billed by time units, making income dependent on client attendance. With caseload caps, no-shows and cancellations have a higher probability of directly cuting into revenue while staff costs remain fixed. Limitations on these proposed units are not realistic based on levels of client need. When provided units are exhausted rapidly due to the unpredictable nature of crises and the requirements of the CPST team to provide the crisis support, this leaves gaps in the ability of the agency to receive appropriate reimbursement to sustain the service.

Heavy training, documentation and prior authorization requirements add unreimbursed staff hours and significant burden on the company and staff providing the service. High-stress, high-acuity, community-based work leads to burnout and turnover. Recruiting and training replacements increase expenses. Overall, implementing CPST as a proposed alternative to the legacy services does not appear to be a financially sound decision for companies both related to their bottom line and ability to sustain staff.