As a Licensed Professional Counselor (LPC) and Regional Director of Therapeutic Day Treatment (TDT) services across several rural counties, I am deeply concerned about the proposed replacement of TDT with Community Psychiatric Support and Treatment (CPST). This plan does not replicate the scope, structure, or intensity of TDT and risks leaving our most vulnerable youth without critical supports.
TDT provides up to 25 hours per week (sometimes more) of structured, therapeutic intervention. This intensity allows for consistent daily support, relationship-building, skill reinforcement, and real-time crisis intervention within the school environment.
CPST is capped at 28 hours per month, which equals no more than 7 hours per week—a dramatic reduction in available service hours. Even at the maximum, students will receive less than one-third of the support they currently receive in TDT.
For students with serious emotional and behavioral challenges, daily repetition and structure are critical. Progress often comes from ongoing interventions, frequent redirection, and consistent therapeutic presence. Reducing contact hours undermines the therapeutic process and threatens student stability.
Daily therapeutic engagement cannot be replicated in 1–2 hours per week. Students who require immediate in-school support for behaviors, crises, and peer interactions will be left without appropriate interventions when they need them most.
Students at risk of hospitalization, removal from school, or homebound placement often rely on the daily structure of TDT. Scaling down to weekly or biweekly contact leaves them vulnerable to escalation and regression.
This change represents not only a service reduction but also a fundamental shift in the level of care available to Virginia’s children. CPST and TDT are not interchangeable; they are designed to meet different levels of need.
TDT provides year-round structure and therapeutic engagement, including summer programming that ensures continuity of care when students are not in school. This consistency is critical, as many children rely on TDT to maintain emotional stability, reinforce behavioral skills, and prevent regression.
CPST offers no summer programming, leaving students without services for an extended three-month period. For children with significant behavioral and emotional needs, this gap is not just inconvenient—it is destabilizing.
Summer is often the most difficult time for our students. They lose the routine of school, experience increased unstructured time, and face greater family or community stressors. Without therapeutic programming, crises and hospitalizations frequently rise during this season.
The expectation that students will return to school in the fall, after three months with no support, and demonstrate improved behavior or sustained progress is both unrealistic and harmful. Many children will regress significantly, undoing months of therapeutic gains achieved during the school year.
Without summer services, schools and providers are forced into a cycle of crisis management each fall, students re-enter needing intensive stabilization, educators become overwhelmed, and mental health providers must “start over” rather than build on existing progress.
This gap in care disproportionately affects students in rural and underserved communities, where alternative resources such as outpatient programs, community groups, or private providers are already extremely limited or inaccessible.
Eliminating summer therapeutic programming represents a major service gap that places vulnerable youth at increased risk of crisis, academic failure, and long-term negative outcomes.
CPST requires at least 8 hours per month of parent/guardian involvement.
While family engagement is important, many TDT families have minimal involvement due to work, transportation, or personal barriers.
Requiring this level of participation will exclude many students who need services the most.
This will also be a major barrier for clients who have unstable guardians or unstable living arrangements or even guardians who are already reluctant to participate.
TDT currently requires WEEKLY contact, but not 8 hours per month. This is unrealistic for school-based services to have parental involvement at this level and frequency.
The purpose of school-based services is to target this environment, where parents/guardians aren’t involved at a higher level. Schools may also not allow for parents to attend in school sessions at this rate, as this can pose school campus challenges.
Virginia already faces a severe shortage of licensed mental health providers. Rural areas are hit the hardest. Families often wait months for outpatient appointments or psychiatric evaluations. Agencies are competing for the same small pool of licensed professionals, making recruitment and retention increasingly difficult.
Rural communities are disproportionately affected. In many of the counties we serve, there are few, if any, alternative providers. If agencies cannot staff CPST adequately, children simply will not receive services at all.
CPST requires more highly trained and licensed staff than TDT. While this raises the clinical threshold, it also significantly limits the number of available practitioners. Burnout and turnover are already high in behavioral health. The work is emotionally taxing, underpaid, and administratively heavy. Adding higher documentation demands, crisis intervention responsibilities, and unstable caseload requirements under CPST will only worsen the problem, driving more providers out of the field. Our current system and documentation requirements have already caused many clinicians to leave altogether.
When agencies cannot keep positions filled, vacancies and staff turnover create service instability. Children experience disrupted care, shifting caseloads, and broken therapeutic relationships. This undermines trust, slows progress, and increases the likelihood of crisis escalation.
Requiring LMHPs to complete additional responsibilities such as treatment planning, supervision, and direct service provision on top of already high caseloads further stretches an already limited workforce. QMHPs, who are more than capable of managing many of these tasks (as they have for the past couple of decades), and will be underutilized by these restrictions.
The end result is a service model that is not sustainable. Staffing shortages mean that agencies may not be able to accept referrals, leaving children without services. Staff who remain may face overwhelming workloads, leading to further burnout, resignation, and disruption in care.
Proposed reimbursement rates are below national averages while Virginia has a higher minimum wage than most states. This makes it difficult to pay competitive salaries.
CPST billing depends on client attendance; cancellations and no-shows cut directly into revenue while staff costs remain fixed.
Caseload caps prevent flexibility in service delivery and reduce agency sustainability.
High training, documentation, and prior authorization requirements add unreimbursed staff hours.
School-based integration is one of TDT’s strengths, allowing students to stay in class and succeed academically. CPST does not replicate this school-based support.
Group-based treatment in TDT helps students build social competence and practice skills with peers. CPST lacks this intensive group structure.
Treatment planning requirements for LMHPs further strain an already stretched workforce. QMHPs are more than capable of developing treatment plans, and this change wastes LMHP capacity.
Short authorization periods are unrealistic for youth with complex trauma or severe mental health needs.
TDT and CPST serve different populations. Replacing TDT with CPST is not a true substitution and will leave critical gaps. This redesign represents another cut to children’s mental health services at a time when needs are only increasing. Virginia’s children and families deserve more support, not less. Eliminating TDT in favor of CPST is a bad plan that harms students, families, providers, and schools. We urge decision-makers to:
Maintain TDT as part of the continuum of care.
Address workforce shortages with realistic staffing requirements and competitive pay.
Ensure reimbursement rates reflect actual costs.
Ensure the time allow to work with clients reflects what the actual need is for the client (entend the increment time per unit)
Remove unrealistic caseload caps and parental involvement barriers.
Expand services to meet the growing need, especially during summer months.
Virginia’s children deserve better. ALL children deserve better. This plan must be reconsidered.