There are several significant concerns regarding the provision and implementation of CPST. First, the CANS Lifetime assessment is identified as the primary tool, but it is unclear whether it replaces or supplements the CNA. Agencies have not had the opportunity to review it, and training—likely required—cannot feasibly be completed within the proposed timeline, particularly if staffing is not yet established. Additionally, the draft refers to “recommended” assessments, but it’s unclear if these are truly optional or effectively required.

Authorization for CPST appears contingent upon prior referrals to other services and documented proof that those services are either unavailable or unsuccessful. This suggests individuals may need to "fail" elsewhere before being eligible, which raises clinical concerns. Moreover, individuals cannot be authorized for certain other programs (e.g., Clubhouse, Day Treatment, ARTS) while receiving CPST, even if those programs are clinically appropriate.

There are questions about training requirements as well: will mandatory modules need to be completed before implementation? Will ongoing training be offered to maintain annual compliance? Staffing requirements also pose a challenge. CPST mandates LMHP Clinical Directors, Supervisors, and other LMHPs, who are already difficult to recruit. Current reimbursement rates may not support hiring sufficient LMHP and QMHP staff. Supervision demands are also heavy—weekly individual supervision by LMHPs, combined with their own documentation, planning, and supervision duties, may be unrealistic.

The tiered structure and caseload limits are complex and burdensome, requiring formula-based calculations and detailed logs that add to administrative workload. CPST must also provide 24/7/365 crisis support, but the draft indicates that only CPST team members (not agency crisis staff) may provide this. Additionally, CPST providers cannot also offer Mobile Crisis Response or Crisis Stabilization services to the same individuals, creating serious service gaps and barriers to care—particularly for smaller agencies.

Diagnostic criteria for CPST are vague. The use of unspecified ICD-10 codes is allowed, yet LMHP supervisors must have SMI experience, making it unclear who the intended population is. The Medical Necessity Criteria span five pages and, along with the tiered structure, are overwhelming and difficult to interpret. Despite the intensity of service requirements, the draft suggests most individuals would be enrolled in CPST for only 90 days, raising questions about the effectiveness and sustainability of the model.

Ultimately, the proposed implementation timeline is extremely short. It is unlikely agencies will be able to ethically and accurately hire staff, complete training, and establish programs within the allotted time.