Thank you for the opportunity to provide comments on the proposed Community Psychiatric Support and Treatment (CPST) service. We appreciate the Department’s commitment to expanding access to evidence-based, community-based behavioral health services. The CPST model reflects many promising elements that align with best practices in mental health care.

Strengths of the Proposal

• The use of evidence-based models is a welcome advancement for improving outcomes for individuals with serious mental illness and emotional disturbance.
• A team-based approach to care promotes collaboration and continuity, which are essential for effective treatment.
• Family involvement in treatment planning and delivery is critical and consistently leads to better outcomes.
• The inclusion of accreditation requirements supports service quality and accountability.

Concerns and Areas for Clarification

1. Staffing Ratios and Workforce Feasibility
• The proposed staffing ratios are restrictive and may not be feasible given current workforce shortages, particularly among LMHPs. The model limits the role of QMHPs, which could reduce access to care and increase administrative burden on LMHPs and Clinical Directors.
• Clarification is needed on billing practices when both LMHP and QMHP staff are present during service delivery. Should providers bill for both professionals’ time or only one?
2. Service Hours, Rates, and Sustainability
• The proposed rates do not appear to account for the substantial non-direct service time required to deliver evidence-based practices with fidelity. This includes documentation, coordination, supervision, and training.
• The unit allowance may result in reduced service access for some individuals, potentially increasing crisis events or hospitalizations.
• Rates must reflect the full cost of delivering EBPs, including training, oversight, and fidelity monitoring. Without this, providers may struggle to maintain quality and compliance.
3. Model Complexity and Billing Confusion
• While the team-based model is appreciated, the billing structure is unclear. If both LMHP and QMHP are providing services simultaneously, can providers bill two units at each rate?
4. Referral Requirements and Access Delays
• Requiring individuals to be referred to stand-alone EBPs prior to CPST may delay access to care, especially in rural areas where such services are limited or unavailable.
• The process for proceeding with CPST when a stand-alone EBP is not available needs clarification.
5. Training Requirements and Funding
• Additional required trainings (e.g., MAP, Youth Mental Health Rehabilitative Supports and Services) are important, but it is unclear whether the state will provide these trainings or offer funding support. The proposed rates do not appear sufficient to cover these costs.
6. CANS Lifetime Assessment and Additional Assessments
• There is uncertainty around the implementation of the CANS Lifetime assessment. Will all providers be eligible to complete it as currently the only approved providers are local DSS?
• If a client transfers from another provider and the CANS is inaccurate, what is the protocol?
• Can providers use alternative assessments if the recommended ones are not appropriate?

Khuyến nghị

• Delay Implementation: Consider postponing the rollout by at least one year to allow for further refinement and provider readiness.
• Clarify Training Requirements: Provide guidance on who will deliver required trainings and whether funding or grants will be available.
• Revisit Reimbursement Rates: Current rates appear to assume 75%+ utilization to break even. This is not realistic given typical Medicaid outpatient utilization rates (~50%). Rates should be adjusted upward by at least 25% to reflect operational realities.
• Phase-In Utilization Targets: Begin with a 50% utilization target and gradually increase over two years. This phased approach will allow providers to build capacity and ensure service quality.
• Ensure Provider Viability: The current rate structure leaves little margin for cancellations, staff turnover, or other common disruptions. Without adjustment, providers may be unable to sustain services or meet demand.

We appreciate the opportunity to provide feedback and look forward to continued collaboration to ensure CPST is implemented in a way that is clinically sound, operationally feasible, and accessible to those who need it most.