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9/21/25 4:44 chiều
Commenter: Henrico Area Mantal Health & Developmental Services.

CPST proposed regulations
 

Định nghĩa:

CANS Lifetime—it would be helpful for providers to have access to this tool to assess how it may impact workflows, training and certification processes, etc.  CSA adopted a youth version of CANS several years ago and the general consensus has been that it is not helpful.

Early Serious Mental Illness—how would a provider determine initial onset of a diagnosable condition?  If we see someone who has never received treatment before and they report problems with sleep and appetite a  year ago is this the onset period?  Does this still qualify as “early serious mental illness” since they have not been previously diagnosed?

Supervision—suggest striking the first sentence of this definition and beginning with “It is a structured…”   Otherwise it seems like you will need to include a definition of “relationship-based education” in this context—isn’t this term usually used in educational settings?    

Clinical Director—there is a big emphasis on these regs regarding the “clinical director” but this is not defined.  Different organizations define this function very differently.  The focus on this one position does not take into account large organizations that may have multiple layers of administrative and clinical oversight. 

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