am writing to express significant concern about the proposed implementation of CPST services. I am currently employed at a very rural CSB with a catchment area that is over 2,200 square miles. I acknowledge that CPST can be an important tool for supporting individuals with mental health needs however, implementing CPST in a rural area presents several significant challenges that must be addressed to ensure effective and sustainable service delivery. The following concerns highlight key barriers:
1. Time Constraints for Implementation
The proposed DMAS time frame of less than one year to implement CPST creates pressure to develop infrastructure, hire staff, and achieve compliance quickly. Rural areas lack existing systems and workforce capacity to meet these requirements within such a short period. Rapid implementation risks compromising quality and sustainability of services. The change to CPST is a heavily lift for all CSBs and will require careful planning and development for the program to be successful. The time frame does not allow time to recruit staff let alone train them.
2. Low Reimbursement Rates
The proposed CPST service rate is low but staff credentialing is high as are the service requirements (24 hour services). This discourages CSBs from offering CPST in rural areas. Limited funding undermines the ability to attract qualified staff, sustain operations, and provide comprehensive coverage. Financial strain may lead to under-resourced programs, reducing effectiveness.
3. Cost of CARF Accreditation
CARF accreditation is a requirement but is costly to obtain and maintain. Rural CSBs operate with smaller budgets and cannot easily absorb these expenses. Accreditation costs divert funds away from direct services, further reducing available resources for client care. CARF is behind on reviews for CSBs currently accredited and adding the requirement to be accredited in order to provide CPST will further overload the already strained system.
4. Workforce Limitations
The proposed DMAS CPST requirements relying heavily on licensed staff is a significant concern. Recruiting and retaining licensed professionals in rural areas is difficult due to workforce shortages and competition with urban employers. Reliance on licensed staff increases salary expenses, straining already limited budgets. High turnover rates further destabilize service delivery.
5. 24-Hour Crisis Service Requirements
The requirement for CPST staff to provide 24-hour crisis services is a significant challenge, especially when there is a need for face to face crisis intervention. In large rural regions, meeting this requirement means covering extensive geographic areas with limited staff. Travel time for crisis response significantly reduces efficiency and delays care. Rural CSBs will struggle to sustain the infrastructure needed for round-the-clock crisis support that is outside of already established crisis teams or emergency services departments. The need for staff to be available 24/7 is going to increase burnout and increase salary expenses as increased compensation will be needed.

Clearly, implementing CPST in rural areas requires careful consideration of financial, logistical, and workforce challenges. I fear that without addressing issues such as low reimbursement, expensive accreditation, staffing shortages, and crisis response logistics, rural communities risk being unable to provide sustainable and effective CPST services.

Sincerely,
Kelli Jones, LPC