We appreciate the time and effort invested in developing sustainable, effective services that align with fidelity standards. Similarly, we recognize the work that went into creating the initial CPST draft.

As an organization with over 30 years of experience implementing evidence-based practices (EBPs), we have several concerns regarding the current proposal. While the end goal is laudable, the draft contains structural issues that may hinder long-term sustainability and effectiveness.

1. Treatment Intensity and Reimbursement Rates

Establishing a viable, sustainable workforce is essential to achieving the intended outcomes. When comparing the proposed rate structures to those in neighboring states—especially when adjusted for Virginia’s cost of living—it becomes clear that the current rates are insufficient to support EBPs with fidelity or efficacy.

Inadequate reimbursement can lead to:

• Unsustainable caseloads for providers.
• Declining service quality.
• Increased staff burnout and turnover.
• Fragmented or delayed care for families.

To maintain fidelity, reimbursement models must reflect the full scope of care, including both direct and non-direct services.

2. Service Rate Structure

Rates must support both initial implementation and long-term sustainability. This includes:

a. Model Implementation and Ongoing Support

Effective EBP delivery requires:

• Ongoing coaching and booster sessions.
• Fidelity monitoring.
• Reflective supervision that supports clinical growth.

We recommend:

• Requiring fidelity measures and periodic audits.
• Embedding outcome tracking into service delivery.
• Supporting supervision models that promote continuous improvement.

b. Non-Direct Time

Critical non-direct activities must be accounted for, including:

• Treatment planning and coordination.
• Documentation and data collection.
• Crisis response and safety planning.
• Supervision and team collaboration.

These are essential to achieving positive outcomes and must be reflected in the reimbursement structure to ensure provider capacity and workforce retention.

3. Understanding Outcomes and Achieving Accountability

Many EBP’s including Family Centered Treatment rigidly track outcomes and fidelity. These tracking mechanisms require resources and should be considered into the rate structure.

Oversight mechanisms should include:

• Outcome monitoring systems.
• Feedback loops for continuous quality improvement.
• Transparent criteria for evaluating progress and effectiveness.

4. Sustainability and Long-Term Impact

A focus on billable hours risks incentivizing quantity over quality. Instead, reimbursement and staffing models should align with high-quality, evidence-based service delivery.

To promote sustainability:

• Incentives should reward fidelity, outcomes, and workforce development.
• Funding models should support long-term capacity building.
• Policies must reflect the true cost of delivering EBPs with integrity.

We fully support Virginia’s goal of expanding access to effective, research-based, community-based services. There is a real opportunity to lead in the thoughtful implementation of EBPs—but this requires a realistic understanding of what it takes to deliver these services well.

Financial models that support this work already exist and can be shared. Providers need support not only in training, but also in infrastructure, supervision, and financial sustainability.

We urge policymakers and stakeholders to consider these recommendations as part of a broader strategy to strengthen behavioral health services across the state. We would welcome the opportunity to share our national experience in implementing EBPs with sustainability and fidelity.

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