Claims and program data show a dramatic reduction in access to Therapeutic Day Treatment in Virginia over the last several years. Let me be clear- this is a reduction is access due to the following barriers, not a reduction in need nor effectiveness and value of the service.

The DMAS draft definition for CPST emphasizes clinical contacts, caregiver engagement, and community-based delivery but does not provide opportunities for the daily, in?school presence that makes TDT effective for high?needs students. Given workforce shortages, funding instability, and documented benefits of intensive in?school programs, replacing TDT with CPST as currently drafted will likely increase behavioral crises, suspensions, absenteeism, and long?term costs to schools and families.

Top concerns (without addressing the ridiculous training, documentation, supervision, and logistical cpst requirements):

1. Large loss of prior TDT capacity. State claims data show an ~80%+ decline in TDT membership counts in recent years, indicating many students lost access to intensive, structured in?school supports. This decline was driven by managed care carve?ins (2017 onward), reduced reimbursement rates, higher administrative requirements for authorization, and stricter medical necessity criteria — all of which discouraged provider participation and limited access for students.

2. Workforce and geographic gaps. Virginia and national reports document shortages of behavioral health providers and concentration of vacancies in many localities — limiting CPST supply, particularly for in?school coverage.

3. CPST requirements create access friction. The draft emphasizes caregiver engagement, repetitive clinical authorizations, and service documentation — all of which raise barriers for low?resource families and slow service startup/continuity.

4. Evidence favors consistent in?school presence. Systematic reviews and day?treatment studies show the biggest school outcomes when services are delivered consistently within school settings; removal of that presence correlates with higher suspension and disruption risks.

5. Funding instability risks program attrition. Many school divisions expanded mental health staff with one?time or temporary funds; as those funds expire, intended CPST coverage (if even feasible) is at risk of being reduced.

Potential outcomes of current plan:

More suspensions, expulsions, and out?of?school removals. Why- lack of on?site therapeutic de?escalation and daily behavior support; teachers/administration forced to manage crises.

Academic decline and higher absenteeism. Why- students with unmet behavioral/mental health needs are less able to access instruction, leading to falling achievement and missed school days.

Increased use of higher?cost systems. Why- untreated or intermittently treated students are more likely to require emergency services, hospitalization, juvenile justice, or special education—raising system costs.

Equity gaps widen. Why-caregiver?engagement and travel/time requirements disadvantage low?income, rural, and single?caregiver families.

Long waits and large caseloads. Why- workforce shortages produce long waitlists, brief contacts, and reduced treatment fidelity.

Requests: 

1. Immediate moratorium on planned TDT cuts until parity is demonstrated. Require DMAS to publish a comparative access and outcomes plan showing CPST can match TDT capacity and outcomes before eliminating TDT.

2. Fund (appropriately) and pilot in?school CPST delivery. Allow CPST to be delivered via embedded school contracts (not just clinic/community visits) and fund pilot sites in diverse divisions (urban, suburban, rural) with outcome monitoring.

3. Relax family?engagement penalties and requirements. Where caregiver involvement is not feasible, allow alternative engagement strategies (tele?family contacts, school?based participation) so students are not denied services.

4. Stabilize funding for workforce development. Provide multi?year grants for recruitment, loan?repayment, and school?based clinician salaries to ensure sustainable staffing.

5. Measure and report outcomes publicly. Require quarterly public reporting (by division and DMAS) on access, wait times, suspension rates, school attendance, and clinical outcomes for youth receiving CPST and youth receiving TDT.

At a time when youth mental health concerns are at an all time high, when violence in schools is no longer a rare occurrence, when needs continue to outweigh provider availability- how is removing a vital support beneficial? TDT should be adequately funded, reimbursed, accessible, and staffed. That would be the appropriate redesign of the service.