thank you for the opportunity to express our concerns, ask questions, and provide feedback.  

2.2 families have to be willing to give 30 minutes a week and the services for youth are meant to only be 4-12. However, many children need mental health services because of family dynamics. This harms the children who have parents who can’t participate weekly. Also if the setting is in the school-setting, the parent is not going to be present and isn’t supposed to be present during the school (or their work day).
CANS is not a reliable assessment tool and does not render consistent results across the service system, there isn’t inter-rater reliability. If you can’t get a reply to a question, there is no option to leave it unmarked or blank, thus skewing the rating. If the CANS is not totally replacing the CAN, does an individual have to go through both to get more than one service?
The Clubhouse Model is very expensive to implement and DMAS or DBHDS is not offering additional funding to cover the cost, making it prohibitive to provide.
CARF accreditation is very expensive to implement, sometimes costing more than actual reimbursement in a year. It is a prohibitive cost. We are already licensed by DBHDS and therefore, the amount of oversight and auditing is even more overwhelming and continues to be unfunded.
In rural areas or smaller entities won’t have the funding to offer multiple specialized EBTs, such as MST or FFT and so individuals will be treated differently and have different resources than urban areas with more provider options.
3.2 & 3.3What does Clinical best practice guidelines mean? Could you provide an example of this? Is the training a one and done, if not what is the frequency?
4. There are already Boards of Health Professionals and standards for supervision. Will there be funding to have an LMHP on-call 24/7 to CPST providers? This is not budget neutral for providers. Is there funding for the CPST LMHP having to go out in person? These are community-based services, not 24/7 services. CPST are not ACT or residential services or crisis services.
4.3.6 individuals may see an LMHP for OP who is in no way involved in CPST. How can provider entities operate and manage the expense of this?
4.5.2 Is there additional funding or reimbursement for supervision? What if the LMHP is providing their licensure clinical supervision, but not their CPST LMHP supervisor? If someone has to have supervision by separate people, this significantly decreases time for service provision and ability to earn reimbursement so the provider entity can actually operate a program.
4.9 What will the formal log look like? Can you all provide an example?
5.1 If the CANS is to be performed more than once a year, will it be reimbursed each time it is completed?
5.2.7 has reimbursement increased to fund a clinical supervisor, the CPST team and individual to attend a quarterly review of the treatment plan? Is this a billable service to cover the expenses of all staff present?
7.7 4-12 months is very limiting, it cant take months to build therapeutic rapport with someone
5.3 Not only will need to have funding to have on call staff but also to hire more staff- higher level staff to provide these services, such as skill building counselor, we will need more vehicles for more staff to provide services in the home. The additional training – will this be an additional cost for us?
5.3.2 Will need to develop our own crisis plan for these services that does not include use of or referral of comprehensive crisis
5.3.7 In person crisis support must be provided by the CPST provider – how would we be able to ensure this, as individual can reach out to crisis. . What about in situations when the individual needs a crisis stab unit rather a CPST counselor. We develop 988 # and now these individuals shouldn’t use this resource?
Why are crisis services being limited for this service but is not limited in other programs such as ACT?
5.4 What is the difference between training and practice? How do you train someone without practice?
5.7.1 Psychotherapy being provided under this CPST code is a lower rate than under outpatient. This also does not take into account for cost of traveling to the home.
6.3 Is it a typo when it says July 1.2025? Why does it also only give us 18 months versus the previous stated 2 years? If we are only awarded a 1 year rather than 3 year accreditation will we then have to pay the fee again in a year?
6.3 Could being a CBHCC meet the accreditation requirements?
7. Staff will have to be CANS trained, which is a cost of time lost by staff.
7.6 if individual is not making progress within 90 days a new ISP will need to be established. Will we need a new authorization every 90 days? Why do a quarterly if you have to do a new authorization?
What will be the authorization process for needing to move an individual between tiers? Will it be fluid or will there need to be two different authorizations?
Anytime there is a change is a new CANS required?
8.2.b reads as though it is saying CPST individuals will not be able to receive Mobile Crisis response, 23 hour crisis stab or residential crisis stab – no matter what. Perhaps, this is just written poorly and it’s suppose to read the services can’t be received concurrently.
8.2.d.iv Requesting some clarification, if CPST cannot receive Clubhouse model Psychosocial Rehabilitation at all or does this just mean not concurrently?
8.3.b Why limit to one hour a week in the office, if individual would prefer not to do it at home? Due to confidentiality issues in the home, they need to use washer at the office or printer? What does covered service components mean?
10. Can a QMHP enter the plan, if LMHP approves the service? Is approving the service considered a co signature? Contradictions throughout regarding who can develop and authorize the ISP. Please clarify if QMHP can develop the plan and LMHP must oversee or must LMHP develop the ISP.
Non licensed cannot bill more than 504 CPST hours? If on call is being required for this service, why is there a cap on units?
Lastly, we don’t feel there is enough time to implement these changes fully and complete costly accreditation by two other entities, even though we already have licensing and oversight by DBHDS and DMAS. 

Developing and implementing the CCBHC model with a PPS in Virginia is much more efficient and effective plan, and in line with national tried and tested trends in quality and data-based treatment.