2.0 Concern around only the LMHP writing the ISP; recommendation to allow LMHP-E. The LMHP is often the supervisor or manager and adding this task for all clients in a program would be burdensome. LMHP-E are currently able to assess for all services. Creates a workforce issue.
3.0 Concern around the cost and associated training costs for providing EBP within these rates.
3.2 Need more information on how you will assess or determine success and if someone has to be referred to another EBP.
3.3.2 Concern around requiring Supervisor/Manager to be trained in CBT type, unsure of how this is relevant to their job duties, especially if not supervising an outpatient therapy team.
4.3 Requiring a LMHP to be available 24/7 for consultation and to provide services once every 90 days. Licensed providers are scarce and often employed as Supervisors or Managers. This seems an additional unnecessary burden.
4.4 Weekly F/F meeting with teams seems to be excessive: suggesting monthly team meetings and monthly individual supervision.
4.5 Concern regarding number of reports. Licensed staff are scarce. I would suggest a 10-12 range due to staffing concerns and budgetary constraints.
4.5.3 Requirements for QMHP supervision seem to be excessive; recommend bimonthly supervision for QMHP and weekly for QMHP-E.
4.6 Caseload caps seem low and not totally feasible given the proposed rates. Also concern around billing limits for non-licensed staff as QMHPs constitute the majority of CSB direct service staff.
5.2 Concern regarding LMHP signing ISP. This seems an unnecessary additional burden; recommend person carrying out treatment sign with the individual. Requiring LMHP to be present for QR seems an additional burden again with limited licensed staff in primarily leadership roles; recommendation QMHP and client complete QR, LMHP reviews/signs QR.
5.3 Requiring CPST staff to respond to crisis seems duplicative of having a crisis continuum that was just built out and added to and promoted and pushed for. This is huge staffing burden requiring training all staff who have previously not provided crisis services. This would be time consuming and costly.
7.4 Requiting anyone seeking CPST services to have first tried/had psychotherapy seems unrealistic and unfair to individuals. Psychotherapy requires licensed staff that are scarce. Therapy is not a one size fits all intervention, not everyone volunteers or is interested in therapy as such this should not prevent individuals from other services they need or would benefit from.
7.3 Need further explanation of the level of need within the tiers.
7.7 The timeframes for services seem unrealistic for the population we serve; would recommend as long as there is clinical need and success in treatment.
8.0 Individuals cannot engage in SUD services while engaged in CPST. This does not make sense and seems restrictive. Individuals need access to services of different types to achieve recovery.
9.2 Requiring an ISP to be submitted with authorization? This does not seem realistic. It takes approximately 1.5-2 hours to fully assess individuals and complete all necessary measures and paperwork. Individuals become restless and impatient already, to then add on completing an ISP with someone who is not going to be completing the service does not seem efficient or practical.
10.0 LMHP has to either provide services every 90 days or sign all QMHP progress notes? This seems like a huge burden given that majority of service providers in CSBs are QMHPs. LMHP are typically supervisors and managers within CSB and holding a caseload and providing services is not feasible with all the other duties.