“CPST is delivered by two or more members of a team consisting of professional and paraprofessional staff…” Does this mean an LMHP can not do the role of assessing, service implementation, ect without the help of another staff? (on page 3, 2.1 CPST Teams, CPST Tier One Team #1 & CPST Tier Two Team #1 is the LMHP as the Supervisor and LMHP as the Staff Type. Does this mean the same LMHP can not be the Supervisor and main staff type on the case?)
Are we to assume the “Professional” is the staff holding a license, like the Licensed Mental Health Professional, not Resident/Supervisee? Even though QMHP is not in the definitions, the “P” in QMHP also stands for “Professional” so this is confusing without a definition for “Professional” and “Paraprofessional.”
“A license mental health professional completes trauma-informed assessments…” Can an LMHP-type not do the assessments?
“A license mental health professional… develops individual service plans…” Can an LMHP-type not complete the service plans?
Page 3, 2.1 CPST Teams
QMHP-T is not listed in the Tier Two chart.
At the end of the day this was probably a mistake, but also seems like it was initially done on purpose and they did not agree with the Board of Counseling’s decision to approve a QMHP-T and instead of pulling the QMHP-T out of services all together (knew they would get back lash, since it took a lot of time and dedication to get the QMHP-T registration passed) they just decided to group the QMHP-T with the BHT. This is a huge step backwards for future QMHPs to get the needed training and hours in order to become a QMHP, while also trying to sustain a living. This will greatly hurt staffing.
Potentially/likely, providers will not have the ability to serve many Tier Two members. The only service a QMHP-T can do within this redesign is the rehabilitative skills practice which will not take up many hours. It will be very difficult for a QMHP-T to achieve 1500 hours of supervised experience within the 5 year time frame they are given.
QMHP-T has 5 yrs = 260 wks / 1500 hrs of supervised experience = 6 hours a week at minimum (not including being off on holiday weeks/ sickness/ vacation/ client unavailability/ ect.)
This is a huge step backwards for future QMHPs to get the needed training and hours in order to become a QMHP, while also trying to sustain a living. This will greatly hurt staffing.
Under Supervisor some teams say “LMHP Clinical Supervisor” and some say “LMHP Clinical Supervisor (provides all service components that require an LMHP-type).” Does this mean there is no team scenario where you can have an LMHP Clinical Supervisor, an LMHP-R/S/RP completing assessments/treatment planning/psychotherapy, and an LMHP-R/S/RP completing the other service components left? If this is correct, that means in the above scenario with a LMHP and LMHP-type, the only option for that third staff type would be a less qualified staff member(s) (Tier 1 - QMHP or Tier 2 – QMHP or QMHP with QMHP-T/BHT) doing the other services components left? I am not seeing the benefit or reasoning for not allowing a LMHP-type to do the other services when an LMHP-type is covering the assessments/service planning/psychotherapy role.
Under 2.3, it states “When services are delivered to younger children, the majority of the services must be delivered with a caregiver…” Our recommendation is to define what is considered a younger child vs older child in services.
Required Evidence-Based Practices
3.2
How long must the client wait from date of referral to the stand alone EBP programs to get a response or to start treatment before they can explore CPST services? How does a provider prove/document the client was referred to and/or received stand alone EBPs but they did not work or could not be offered?
Because of this, it leads to the potential of the client unknowingly receiving multiple CANS Lifetime Assessments by multiple providers within a certain amount of time. Will the provider have to contact the MCO before they complete every CANS Lifetime assessment for a client? MCOs are not always easy and non-time consuming to get in contact with. The MCO portal is though, will that be an option to search for if the client has previously received a CANS Lifetime? Will the MCO be able to communicate with the provider that a CANS Lifetime has already been completed and supply us with the copy? I assume the MCO will not be able to tell us what provider provided the CANS Lifetime and thus we will not be able to communicated questions on interpretation of their answers. Can a CANS Lifetime Assessment still be billed and reimbursed to the new provider if another company has already billed and been reimbursed for a CANS Lifetime prior? A concern is, if the client qualifies for the stand alone services it will be a lot of unpaid work going back and forth trying to get the client services and in the end a lot of clients who need the services just won’t receive the services. We feel this will be a big barrier to getting services for clients who are in need and within the time frame needed.
If an individual is not making progress in CPST after the authorization period, they have to be referred to an appropriate EBP? What if the client does not have access to the appropriate EBP?
Even when there is only one company completing and billing a CANS Lifetime, the hours needed for the service verses the one time billing rate reimbursement will put providers in a hard position where they won’t be able to reimburse staff at a rate needed to adequately meet the quality staffing needs.
Required Services Oversight and Supervision
LMHP-Type (Resident or Supervisee) will no longer be able to supervisee QMHP/QMHPT staff. This will greatly hurt the providers ability to give services because of staffing needs being harder to maintain by this added barrier. A lack in adequate behavioral health workforce has already been a common known theme of concern, especially in terms of number of qualified staff available. Not many fully Licensed staff want or are able to do this work. They normally do this type of work while they are getting the experience and the hours to become Licensed. Once Licensed they do not need to travel and go into a client’s home in order to do this level of service for the amount of pay that Medicaid is willing to reimburse. Because of the job circumstances providers have a very difficult time (sometimes an impossible time) finding, hiring and keeping good licensed staff to do the supervision role with these services.
5 Required Service Components
5.7.1 Psychotherapy – Our recommendation is to allow providers the option to coordinate care with outside Outpatient Therapists that provide Psychotherapy to the client instead of requiring the Psychotherapy services be completed by the same provider who is giving CPST services. The coordination of care can still be documented in the ISP and chart, but not mandatory for the CPST provider to directly give the Psychotherapy to the client if an outside option is more beneficial for the client. The concern is the duplication of current Outpatient services the client might already be connected to and allowing the provider to help the client find and engage with a longer term Outpatient Therapist that can help even when CPST services are complete. This allows for the on going support to keep the client out of more intensive services later.
CPST Billing Requirements
Billing with multiple different modifier combinations depending on the level of staff member and/or level of service will take a great deal more time administratively. On a billing level, tracking/auditing/processing billing rates for a service depending on the component of service being rendered is a HUGE change and is going to be a great burden on the agency.
Referring to #3 on last page (25) - Tracking a staff’s hours monthly to make sure they do not go over the monthly maximum billing hours will take a great deal more time administratively. On top of that, if they work for another provider this will need to be considered. Besides trusting the staff member to tell us, this is putting a lot on the provider and their administrative support team. As a provider we already make sure staff are not over working themselves, but we do not think giving a staff a maximum set of units in a calendar month is a good way to achieve this goal. It will also add a huge burden on administrative staff.
