Public Comment for VA DMAS re: CPST September 18, 2025
Chào buổi sáng,
I appreciate this opportunity for public comment. As a consultant to state IV-E entities, private provider agencies, and a nationally recognized EBP program, I would like to add comment on specific areas of reform that lead to success and sustainability as you consider changes to CPST.
Costs of success and ROI:
Fiscal considerations are paramount in redesign along with treatment goals and outcomes. Intensive in-home behavioral health services are demonstrated to cost less than out of home care such as foster care, therapeutic foster care, congregate care, and hospitalizations. Data supports this conclusion.
Workforce:
Many states allow for BA level practitioners to be eligible for equal compensation to licensed practitioners. Such provision, even at the same reimbursement levels of licensed staff, goes a long way to workforce retention. Under proper and frequent supervision, data from evaluations of Family Centered Treatment demonstrates that BA level practitioners have equal outcomes/success as licensed staff, are more stable in employment, and allow for better matching of client/family to demographics such as location, ethnicity, and other factors integral to engaging with a family.
Accountability:
Designations such as “EBP” and “trauma informed” are successful and sustainable only when implemented with consideration to scalability, fidelity, measured outcomes, data collection, sustained family involvement, and workforce satisfaction. Many EBPs do not have a bedrock of implementation science that has planned for longevity, sustainability, and fidelity.
In addition, on-going of supervision quality/engagement and identification and fidelity of defined outcomes determine “success” and ROI.
Rates: All implementation and program costs should be accounted for when providing intensive in-home services. Direct costs include: training, certifications, technical assistance, and data collection. Indirect costs include: start-up investment, state licensing and accreditation requirements, and supervision.
These lists of direct and indirect costs are not all-inclusive, but examples that determine success, sustainability, and return on investment for the State.
Thank you again for this opportunity to comment on the proposal. I welcome your comments, questions, and further discussion.
Trân trọng,
Laura Boyd, Ph.D.
Policy Director
Family Centered Treatment Foundation
405-503-1123