Page 5, 3.1 – CANS Lifetime is required however many CSBs Same Day Access conduct comprehensive assessments across many services.  There will be an administrative burden for SDA clinicians to conduct the CANS for CPST and CNA for other services.  This will also add time to the assessment process.  Please consider allowing the CNA for CPST services.

Trang 5, 3.2 – What about provider choice (an individual wants CPST but refuses ACT or Clubhouse or CSC)?  Recommend change to offer but not referred to an EBP before submitting auth for CPST.  There is a gap between individuals who would benefit from 2-3 years of CPST services and individuals (depending on the presentation of their illness) who meet criteria for ACT, MST, Clubhouse, FFT or MST.  These five EBPs do not cover the entire population served and individuals would fall between the cracks. 

Page 6, 3.2 – What if individual is not appropriate for an EBP but not making progress?  Please keep in mind that SMI is persistent and chronic but may not need ACT LOC. For youth, bxs could persist given changes in home or environment but not appropriate for EBP.  Heavy promotion of EBPs marginalizes some individuals who do not meet criteria.  In community mental health, we are serving people with complex issues (trauma, poverty, homelessness, etc.) and don’t always fit into EBP.

Trang 8, 3.4 Required Documentation – recommend that this information be demonstrated during audit…not requiring annual submission to CEP-VA (administrative burden)