The items listed below are just a few of the concerns and questions I have regarding CPST, its provision, and implementation.
The CANS Lifetime assessment is identified as the primary assessment. It has not been made clear if this will be in addition to, or in place of, the CNA. The CANS Lifetime assessment has not been provided for Agencies to review. The CANS requires training to administer and complete. This leads one to believe that the CANS Lifetime will as well. There is not time to review and have staff trained in the timeframe identified for implementation, if we have been able to hire and establish a team to provide the service.
Additional assessments are “recommended.” Does that really mean required?
Individuals must be referred to other services prior to being authorized for CPST. Proof and explanation of those services not being available, or failure of those services, must be demonstrated prior to authorization of CPST. It also implies that individuals must fail at one service to be approved for another. How is this beneficial clinically?
Individuals may not be authorized for those same services at the same time as CPST? Other programs, such as Clubhouse/Day Treatment, and ARTS, could be beneficial and clinically appropriate.
Will mandatory modules for required training be required prior to the implementation dates? Will there be ongoing training provided to remain in compliance with the statewide training requirements that must be met annually?
There must be an LMHP Clinical Director, LMHP Clinical Supervisors, and other LMHP staff. LMHP’s are difficult to find. LMHP’s are difficult to find, hire, and train in the timeframes in which this would be required. The reimbursement rates do not seem to be sufficient to hire all the staff, LMHP and QMHP, that would be required to deliver the service.
Clinical and supervisory responsibilities are LMHP heavy. Individual weekly supervision may be difficult and a heavy time requirement for all staff when the LMHP is also responsible for paperwork and treatment planning, and well as receiving their own supervision.
Tiers and caseload limits are confusing. There are tight limits on caseloads. Having to use a formula to determine mixed caseload sizes can be cumbersome. Keeping ongoing caseload logs to present for compliance with caseload limits is another form of added documentation.
Crisis support must be provided 24 hours a day, seven days a week, 365 days a year. The draft implies in places and is very clear in others, that support must be provided by CPST team members, and not the Agency’s Crisis Services. “The CPST provider or any affiliated provider or business of the CPST provider shall not provide Mobile Crisis Response, 23-Hour Crisis Stabilization or Residential Crisis Stabilization to any individual receiving CPST.” This will create a huge obstacle to individuals’ ability to receive necessary, clinically appropriate, services, that could avoid inpatient treatment. This also creates a large burden for those that do not have any other crisis service providers.
Diagnostic criteria is not clear for the service. The draft states a “primary ICD diagnosis that correlates to a DSM diagnosis, or provisional diagnosis as developed by an LMHP when no definitive diagnosis has been made.” The use of very generic unspecified ICD-10 code diagnoses are allowed. This can be interpreted as any diagnosis could be a qualifying diagnosis. The supervisors must have experience with Serious Mental Illness. For whom is this service intended?
The Medical Necessity Criteria are confusing and lengthy. The criteria are over approximately five pages in the draft. The criteria and service in Tiers are again overwhelming and confusing.
There are a lot of tight requirements for a service that appears to be intended to last a very short period of time. The draft implies that the MCO’s intention would be for individuals to be enrolled for a maximum of 90 days.
It would be extremely difficult for Agencies to be able to meet all of the requirements in the timeframe proposed. Hiring staff, obtaining and completing required trainings, setting up and starting programs ethically and accurately takes a greater amount of time attention to detail than allotted.
