A summary of feedback from our members on this section follows:
Clarity and Consistency of Service Design
The CPST team model and tier structure are confusing and poorly defined. It’s unclear how teams are formed, whether two staff must deliver services simultaneously, or how LMHPs balance assessments, authorizations, and direct care.
Terms like “professional,” “paraprofessional,” “younger child,” and “clinically appropriate” lack clear definitions, creating room for inconsistent interpretation.
The omission of QMHP-T from Tier Two undermines a critical pipeline role for workforce development.
Workforce and Supervision Concerns
The model over-relies on LMHPs, requiring their presence on every team, their direct completion of assessments and ISPs, and limiting residents’ and QMHPs’ supervisory authority.
This approach excludes residents and QMHPs from meaningful roles despite existing regulatory allowances. It also risks bottlenecks if LMHPs resign, take leave, or are unavailable, and intensifies shortages by funneling scarce LMHPs into administrative or supervisory tasks instead of clinical care.
Agencies—especially small and rural ones—fear they will be unable to meet these requirements, leading to reduced access and widening inequities.
Service Scope and Intent
Goals suggesting that adults with serious mental illness should “require minimal ongoing professional intervention” are unrealistic and concerning, especially for relapse or crisis care.
The requirement that services for younger children be delivered primarily with caregivers is vague and may result in MCO denials when caregiver participation is inconsistent or not feasible.
The redesign appears to demand high clinical competence while simultaneously limiting professional intervention, which contradicts both the stated goals of “Right Help, Right Now” and the realities of client needs.
Documentation and Assessment Burden
Uncertainty about whether providers must complete only the CANS or an additional comprehensive needs/trauma assessment risks duplicative, time-intensive requirements.
Excessive documentation demands could drain LMHP time further, limiting their availability for direct client care.
Sustainability and Access
The expanded LMHP staffing mandates and supervision restrictions raise costs without added funding, threatening the financial viability of small and mid-sized providers.
Workforce realities—safety risks, travel demands, and high turnover in community-based LMHP roles—make these requirements impractical.
Without adjustments to reimbursement or flexibility, agencies may reduce capacity or close programs, undermining the goal of expanding community-based access.
