The proposed redesign from CMHRS to CPST creates serious risks for adults with Serious Mental Illness (SMI). 

Assessment: CANS is not validated for adults with SMI. DMAS should allow adult-appropriate tools (such as LOCUS or DLA-20) or require CANS to be supplemented with a validated adult functional assessment.

Eligibility: Define “early onset” and “initial onset” clearly, and restore “at risk” as an eligible category to ensure proactive intervention.

Supervision/Staffing: Current requirements undervalue QMHP experience, overburden LMHPs, and make staffing unworkable. Allow experienced QMHP-As to supervise QMHP-Ts and BHTs, recognize years of experience as equivalent to licensure for supervision, and permit group supervision.

Workforce: Requiring LMHP-only supervision will destabilize the workforce. Transitional grandfathering for experienced QMHPs should be included to prevent attrition.

Treatment Scope: CPST must recognize the chronic nature of SMI and permit concurrent treatment for co-occurring SUD and ID/DD.

Crisis Services: CPST participants should retain access to local crisis services without restriction. Limiting access to out-of-region providers disrupts care and increases ER boarding, police involvement, and safety risks.

Service Units: Proposed limits cut services by up to 87 percent compared to current CMHRS. This will increase hospitalizations and crises. Maximum units should be increased (for example, 120 units/month with exceptions available) and inconsistencies clarified.

Safety Planning: All CPST safety plans must include escalation pathways to higher levels of care, including crisis units, inpatient, and 988.

EBPs/Referrals: Referral options are narrow and do not meet the needs of the SMI population. Expand allowable EBPs and ensure referral processes do not create barriers to CPST admission.

Administrative Burden: Allow QMHP staff to complete documentation under LMHP oversight, and align requirements with existing DBHDS/DMAS standards to avoid duplication.

Summary: Without these changes, CPST will reduce service intensity, destabilize the workforce, and increase psychiatric hospitalizations. Revisions are needed to ensure that CPST is clinically appropriate, workforce-sustainable, and responsive to the needs of Virginians with Serious Mental Illness.