There are serious concerns with how individuals currently enrolled in PSR will transition to CPST or Clubhouse. Very few individuals enrolled in PSR could successfully transition to a Clubhouse model with a reduction in hours per week. Many individuals successfully maintain independence in the community with the support they receive by a day program model where they have the clinical support of staff and the relationship building component with their peers. CPST and the Clubhouse do not offer this level of support that will be lost with many of the individuals in PSR.

In section 3.2, there is a requirement to refer to a standalone EBP. There is a lack of model currently listed that are required to refer members to. This is putting individuals at risk if there are not services in place and structure currently to support this model.

DBHDS or DMAS providing no cost or low cost trainings to providers is not guaranteed and puts providers at risk of an unfunded mandate.

While the Department of Health Professions through the Board of Counseling has made flexibility on allowing experienced QMHPs to supervise QMHP-Ts, the requirements for CPST require LMHPs to provide the supervision. This is putting strain on an already stretched workforce shortage.

There are concerns with the MCO/FFS service authorization model and role of contractors in determining if CPST is an appropriate service.

Please provide clarification on who will provide the Managing and Adapting Practice, Adult Mental Health Rehabilitative Supports and Services, and Youth Mental Health Rehabilitative Supports and Services trainings. What will the initial and follow up offerings look like?

Please provide additional information about the restriction of EPSDT if the MCO determines CPST is the appropriate service.

It will be difficult to maintain staffing levels to allow for CPST employees to provide on-call 24 hour crisis availability. It is assumed there would be multiple CPST teams at an agency. Staffing shortages and funding shortages may hinder the number of staff a provider will be able to have.

Please clarify the expectations around parent/caregiver/family presence in CPST treatment. The drafts states this applies to "younger children". Please define "younger children". It was stated that youth was defined as all youth under the age of 21. Once a person is 18, as long as they have capacity, they can't be required to have parental participation. A minor with capacity is considered an adult at 18 and parental consent is no longer required. The youth model could end at 18 but youth who don't want their parents present may not be appropriate for the adult model.

It is unclear if CPST will be a new program or a subset of the people we serve.  It is unclear who is going to do it and if it is time limited. It is difficult to limit individuals' episode of care so how will this be managed?  Will there be requirements such as Coordinated Specialty Care?  It also seems repetitive to have individuals in this program and also receiving therapy as these providers implement evidence based treatment as well.

Questions for consideration as the policy is revised

• Page 2, 2. Service Definition/Critical Features:  It's indicated CPST is delivered by two or more members of a team comprised of professional and paraprofessional staff.  Are paraprofessional staff defined?  If paraprofessional staff are Behavioral Health Technicians, their role only appears applicable to CPST Teams under Tier Two services, so I'm finding this confusing.
• Page 8, 3.4 Required Documentation:  What is the specific training required in this database?  Can agencies upload training information on behalf of a provider, or will individual providers be required to upload their own training information?  If agencies are required to develop their own clinical best practices (as identified in 3.3.1 Service Delivery specific to Youth and 3.3.2 Service Delivery specific to Adults), can an agency upload policy review documentation for their entire applicable workforce annually or does this also have to be individually uploaded by each service provider?
• Page 16, 7.5 Tier One CPST Admission Criteria:  (a)  If a CPST Tier One Service is on a wait-list, Does this mean the CANS Lifetime Tool has to be recompleted after 30 days before admission can occur when an opening becomes available?
• Page 17, 7.3 Tier Two CPST Admission Criteria: (a)  Same question as above.
• Page 19, 8 Exclusions and Service Limitations: (2)  How can an agency (such as a Community Services Board that provides both CPST services and Crisis Stabilization) ethically and responsibly refuse 23-Hour Crisis Stabilization or Mobile Crisis Response for an individual experiencing a behavioral healthcare crisis engaged in CPST?