I appreciate the opportunity to provide feedback on the draft provider manual for Community Psychiatric Support and Treatment (CPST) services. As a school division leader, I want to express concern about the impact of this redesign on students, families, and schools across Virginia.

As you know, Therapeutic Day Treatment (TDT) will no longer be funded after June 30, 2026. While CPST is intended to serve as a replacement, the proposed model is not equivalent in scope, structure, or intensity. This raises significant concerns about whether the needs currently met by TDT will continue to be addressed.

Key concerns include:

Reduced Intensity of Services – TDT can provide up to 25 hours of therapeutic support each week, while CPST is capped at 28 hours per month. This reduction to a maximum of 7 hours per week represents a dramatic scaling back of direct support for students with intensive needs.

Shift Toward Family-Based Hours – CPST requires a substantial portion of services (at least 8 hours per month) to occur with parents or guardians. While family engagement is important, this reduces the availability of direct school-based support during the instructional day. For many students, especially those with limited family involvement, this creates a barrier to access and could mean losing critical support altogether.

Barriers to Access – Many students who currently benefit from TDT do not have consistent parent/guardian participation. Under CPST, these students would be at risk of losing the intensive behavioral and therapeutic services they need to succeed in school.

No Summer Programming – Unlike TDT, CPST does not extend into the summer months. The loss of year-round support will disrupt continuity of care and leave many students without services during a critical period.

Financial Viability – Based on current modeling, providers estimate they would operate at a deficit of several hundred thousand dollars annually if they attempted to deliver services comparable to TDT under the CPST model. This calls into question the sustainability of the program.

Recommendation:
While CPST may work well in certain community-based settings, the proposed model does not adequately replace TDT in schools. I encourage DMAS to consider modifications that would:

• Expand allowable service hours to better align with student needs.
• Reduce the rigid requirements around family-based hours to ensure access for students with limited family involvement.
• Address the administrative and accreditation burdens that could destabilize the workforce.
• Provide for summer programming to ensure year-round continuity of care.

Without these adjustments, Virginia risks leaving many students without the intensive supports that allow them to remain in school and make academic and behavioral progress.

Thank you for the opportunity to comment and for considering these concerns as you refine the CPST model.