The tier system is confusing. The amount of requirements placed on LMHP are extreme, between the supervision hours, caseload requirements, and documentation. There is an overall de-valuation of QMHP-A staff. 

The restrictive caseload, staffing requirements, reduced units, barriers to access services and complex matrices of requirements paired with the sharp increased requirement for Licensed staff are major barriers to many organizations to consider providing CPST.  The rates which have been presented paired with the requirements of the draft policy make it fiscally improbable that agencies will be prepared to provide this service.

The cost of training is prohibitive as well. More time is needed to undergo this large shift. The cost of Clubhouse Accreditation is $3,800 just to apply, and the process takes 4 years. What will current PSR programs be able to bill for and how once the code of H2017 is gone but the accreditation hasn't processed yet? 

Not allowing participants of CPST to utilize crisis services (appendix G services) if provided by an affiliated business creates a disruption in care.  If individuals must go out of the region to receive crisis interventions like 23-hour, residential crisis stabilization, than the continuity of care is compromised.  This approach creates barriers for individuals at significant risk for getting timely and accurate care.  Individuals will spend more time in emergency rooms waiting for CSU/CRC availability outside of the area.  Transportation to crisis services poses another barrier and safety risk.  Will require more traumatizing response to receive treatment to include ECO and police transport that will likely include restraints.  This is a tremendous liability for very vulnerable populations experiencing acute psychiatric crises.

Please provide clarification of justification for not allowing an individual to access both CPST and Clubhouse Model of Psychosocial Rehabilitation if both services are clinically indicated and appropriate.

The requirement of referrals to the other services listed seems to limit individual/family choice, delay access to needed services, and be inappropriate in situations where one of the listed services is not available in the geographic area.

There is also a concern about the level of power given to the MCO's to be able to outright reject services if they see fit, regardless of what the provider wants. 

The budget neutral rate for clubhouse ($75) is less than the current rate ($89) as it is for all of the other services as well. According to the calculations on the authorization matrix in 9.1 page 23, it would lead to an 85% reduction in support for the individuals my agency is currently servicing, which would lead to an increase in crisis, which will lead to more hospitalizations which will end up costing the state more.