Staffing is quite possibly one of our hardest administrative challenges. In this draft, there are too many variables (2-3 staff, 3 services, and 5 levels of care) with a significant decrease in hours to make it work. 

With this CPST model, providers need more LMHPs. While the Virginia LMHP workforce has been growing significantly over the past 15 years (please see the DHP website for data), there is decreased interest in community-based work in favor of telehealth/outpatient work practice (again, please see DHP website for this data). For the few who are still interested, this job is going to be an even harder sell. Clinically, one LMHP would be guiding/overseeing the treatment of 70 to well over 100 (even close to 200) clients with only 9 supervisees to make this work. Our LMHP-types who currently oversee about 5 IIH cases would be writing treatment plans for as many as 45+ clients (versus 5). This formula would effectively decrease the quality of our services such that one would have to become a “bad” provider to sign up for them, despite the intentional EBP guardrails and MAPs. 

Also, there will not be enough hours for either LMHPs or QMHP/Ts to be full time because decreased and shared hours mean shorter sessions and more travel. For child CPST services, viable session times are around 3:30-8:30pm (if we’re lucky). Here’s the math: as is, there are maybe only 20-22 clinical hours available with travel between clients from M-F. But with shorter sessions and more clients, there are fewer F2F hours and more driving. Of course, this also increases provider costs (back to a bad business model). 

Suggestions to make this viable would be to bundle restorative Life Skills and Rehab Skills Practice into one service, allowing both QMHPs and QMHP-Ts to provide it. Consistent with the Board of Counseling allowances, continue to allow LMHP-types to supervise QMHPs Also QMHP-Ts to provide Tier 1 services. And increase allowable hours, especially to Tier 1.

While many of Virginia's above-board Virginia BH agencies would align with DMAS’ efforts to rid the system of fraudulent providers, accountability by way of new, overly complex rules and regulations (as opposed to holding fraudulent providers accountable to follow previously written rules and regulations) serves only to risk eliminating many if not all providers. This is undoubtedly not the goal and, thus, it is hoped that DMAS will hear that this is the imminent potential effect. And while providers and staff will be without work, the most regrettable consequence will be the lack of services for the growing number of individuals in need of intensive mental health supports in our Commonwealth.

The proposed CPST Program is an excellent fraud deterrent as it is an unachievable business model. However, one would like to think that this is not the intent. The numbers add up to eliminate fraud by eliminating the services. What they do not currently add up to is a viable business model.