An overview of feedback from our members on this section follows:
Confusion and Lack of Clarity
The CPST team structure and tier system are poorly defined, leaving providers unsure how teams are formed, whether two staff must work simultaneously, and how LMHP responsibilities overlap with assessments, authorizations, and service delivery.
Terms like “Professional” vs. “Paraprofessional” are vague, especially when QMHPs are excluded from definitions even though their title includes “Professional.”
Requirements for “younger children” and caregiver participation are undefined, creating risks of inconsistent interpretation by MCOs.
It’s unclear whether LMHP-types (residents/supervisees) can perform assessments, service plans, or psychotherapy, despite current regulations allowing this.
QMHP-T and BHT Roles
The draft frequently references BHTs but excludes QMHP-Ts in key places, raising concerns that QMHP-Ts are being grouped with BHTs.
This limits training and career pathways for QMHP-Ts, making it harder to accumulate supervised hours within the required five years.
Excluding QMHP-Ts from Tier One and limiting their service functions to skills practice diminishes workforce capacity and sustainability.
Supervision and Staffing Burden
LMHPs are required to supervise all staff, with residents excluded from supervisory roles despite their training and current regulatory allowance.
Agencies fear that if an LMHP is unavailable (leave or resignation), services cannot continue—creating bottlenecks.
Given the statewide LMHP shortage, this requirement is viewed as unrealistic and could force small/mid-sized agencies out of the market.
Service Design Concerns
Goals such as “require minimal ongoing professional intervention” are seen as unrealistic and inconsistent with the needs of individuals with serious mental illness.
Restricting LMHP-types from handling major service components reduces flexibility and drives up costs.
The approach of limiting professional involvement while requiring highly clinical teams appears contradictory.
Documentation and Assessment Duplication
It’s unclear whether only the CANS must be used or if a full comprehensive needs/trauma assessment is also required, which would create duplicative administrative burden.
Documentation requirements for caregiver participation are vague, and risks of denial increase if language isn’t clarified.
Workforce and Sustainability Risks
Mandating LMHPs for nearly all functions intensifies hiring challenges and salary competition, particularly with larger organizations and hospitals.
Smaller agencies fear being priced out or forced to reduce services due to higher operating costs with no reimbursement adjustments.
LMHPs already face safety, travel, and burnout concerns in community-based work, which the redesign ignores, making recruitment and retention harder.
