Commenter: Rappahannock Area Community Services Board
RACSB Top 6 Concerns:
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.
CPST guidelines acknowledge this service is for those with chronic mental health issues, but establishes services that do not address the lifelong nature of many individuals' challenges. By not acknowledging the chronic nature of SMI, CPST creates barriers to true stability and recovery. SMI by definition is an acute, persistent, and chronic mental illness.
Currently an individual receiving psychosocial rehab, skill building, and therapy (2x month) at most receives 162 hours of support a month. By new unit maximums the most acute individual will receive just 28 hours a month. The reduction in resources equates to a loss of nearly 87% or 134 hours of care. Such a drastic cut in services will create undue hardships and significantly increase risks for hospitalizations. Current services divert individuals from hospitalization and incarceration. We anticipate an uptick in psychiatric crises.
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.
A crisis or safety plan that does not include access or referral to more intensive level of care is misleading and dangerous. Safety plans are intended to mitigate a crisis when possible but also include numbers and references to resources that may include seeking more intensive support. To suggest a safety or crisis plan cannot include referral to a crisis receiving center is negligent and dangerous.
Co-occurring SUD/ID/DD may receive CPST services but can receive services to address the co-morbid disorder? Ie. An individual with SMI and SUD cannot participate in medically managed detox (ASAM 3.7) while in CPST even though detox and mental health treatment are both clinically appropriate and necessary to support recovery. Psychotherapy is the only treatment provision within CPST that could address SUD. There is nothing within CPST designed to support ID/DD like ABA for those on the Autism Spectrum.
