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9/21/25 4:48 chiều
Commenter: Henrico Area Mental Health & Developmental Services

CPST proposed regulations
 

3.2

“Individuals must be referred to and their needs assessed for any clinically appropriate standalone EBPs of which they may meet admission criteria, prior to the authorization of CPST services,”  What documentation will be required to demonstrate this occurred?  Are all providers expected to know the admission criteria for each of these EBP’s? 

It is difficult to assess the impact of this standard without a thorough working knowledge of the CANS Lifetime.  Does it recommend specific EBP’s or is it more focused on the general type of service? 

“Services that individuals and families must be referred to”  What happens if the individual/family does not want to be referred?   

Are there any geographic limitations on these required referrals?  If I complete a CANS Lifetime in Richmond and it indicates Clubhouse may be appropriate, but the closest clubhouse is in Virginia Beach, do I have to refer them? 

Suggest removing Clubhouse from the list.  For agencies that choose not to adopt the Clubhouse model, this forces them to refer to a Clubhouse rather than CPST.  Isn’t there a DMAS Requirement that you may not require a member to go to one service in order to access another service? 

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