1. Administrative Burden and Compliance Risk:  The CPST model introduces excessive documentation and billing requirements that divert clinicians from direct care. The lack of clarity around compliance standards and audit protocols increases risk for agencies, particularly when QMHPs are shared across organizations.

 2. Workforce Shortages and Caseload Pressures:  Virginia’s behavioral health workforce is already stretched thin. CPST demands exacerbate burnout and turnover, especially when staff go on leave or agencies operate short-staffed. This leads to inflated caseloads and compromised care.

3. Time Constraints and Loss of Person-Centeredness:  The rigid structure of CPST leaves little time for meaningful engagement with clients. Clinicians are forced to prioritize billing regulations over therapeutic care, eroding the person-centered approach that should be central to recovery.

4. QMHP Training vs. Scope of Practice:  QMHPs are expected to deliver high-level psychiatric interventions, yet the training required to provide this care is not available.  Providers are already grappling with needing to make sure QMHPs obtain 60 hours of didactic training, with no options to provide these training hours.  Providers will continue to bear the brunt of the financial strain of needing staff, trying to hire that staff, but then also not being able to adequately train the staff.

5. Unclear Assessment Requirements and Billing Confusion:  It remains ambiguous whether all assessments are required for every client, leading to inconsistent practices and potential billing denials. Cross-agency billing for QMHPs is also poorly defined, creating financial and operational inefficiencies.

6. Regulatory Ambiguity Between Tier 1 and Tier 2 Services:  The distinctions between Tier 1 and Tier 2 care are vague, leaving providers unsure about eligibility, documentation, and service delivery expectations. This undermines consistency and accountability.

7. Crisis Support Integration Gaps:  CPST does not clearly align with Virginia’s crisis response systems, including Marcus Alert and Mobile Crisis Teams. Without seamless coordination, individuals in crisis may receive fragmented or duplicative care.

8. Chronic Underfunding:   Despite its ambitious scope, CPST is not backed by adequate funding for staffing, training, infrastructure, or quality assurance. Providers are expected to do more with less, which is unsustainable and unethical.  Studies were done to determine what the care would cost, and the price point chosen was below the median.  Quality care can never be given when reimbursement rates are below the median.   

The CPST proposal, as currently designed, is misaligned with the realities of community-based mental health care. I urge policymakers to reconsider their implementation until these concerns are addressed through clearer regulations, adequate funding, and meaningful stakeholder engagement. Without these changes, CPST risks becoming another bureaucratic layer that hinders—rather than helps—those in need.