Section: 7.1 CPST Medical Necessity Criteria

• The requirement to demonstrate that standard outpatient therapy of one hour weekly for three months was not sufficient could delay clinical appropriate level of care by require an individual to first access a level of care that is insufficient.  Further, that level of outpatient care may not be an available option in the area or have significant waiting lists, further restricting access to needed services.

Section:  7.3 Tier Two CPST Admission Criteria

• Is the “at-risk” eligibility criteria not eligible for Tier Two service?
• The requirement to demonstrate that tier one services was not sufficient could delay clinical appropriate level of care by require an individual to first access a level of care that is insufficient. 

Section: 7.4 Additional Tier Two CPST criteria for youth

• Does the requirement for family/caregiver to commit to participating in 2 hours of CPST services a week apply to school-based supports?  Is the individual not eligible for this service if the family/caregiver is not available at that level.

Section: 7.6 Continued Stay Criteria

• How is “not making sufficient progress” measured to trigger need for alternative service plan within 90 days.  Is 90 days sufficient time to make “sufficient progress”?
• How does the requirement of expectation of improvement at current level of service if individuals are at baseline but still meet the eligibility criteria?

Section:  7.7 Discharge Criteria

• How does the recommended max of twelve months of service impact access for individuals with persistent, serious mental illness which will impact the individual long-term and requires this level of support longer than one year in order to avoid the need for higher acuity, higher cost services?