In general, these proposed policies significantly increase the administrative burden on providers without commensurate increase in reimbursement rates.  Many of the goals of these policies appear to be to restrict/control providers to eliminate fraud and inappropriate billing for services.  While this is an admirable goal, it is better achieved through increased oversight and monitoring than it is by creating policies that will be difficult to implement and monitor. Many of the evidence based models that are identified are expensive to operate—both due to training and ongoing consultation.  MST is a good example of a really good service that is really expensive to operate.

It also seems odd that there is such a strong emphasis on evidence based practice for a service, CPST, that is not evidence based.  Would it be more efficient just to provide specialized reimbursement rates for EBP’s, similar to what is done for ACT and MST?