A summary of feedback provided by our members on this section follows:

Lack of Clarity in Eligibility and Criteria

• Providers don’t have enough information on the CANS Lifetime tool to evaluate its use.
• Contradictions exist (e.g., DDs and SUDs are DSM diagnoses—does eligibility require only MH diagnoses?).
• Ambiguity around demonstrating that outpatient therapy or Tier 1 was “insufficient”—is prior failure required, or is clinical judgment enough?
• Functional impairment criteria (2 domains vs. 3 domains) are confusing and need simplification.

Service Hours and Length of Stay

• Tier 1 (4–6 hrs/month) and Tier 2 (7–28 hrs/month) provide far fewer hours than legacy services like IIH or MHSS (8–15 hrs/week). Providers fear these caps cannot meet client needs.
• Length of stay (4–12 months) is too short for meaningful progress in many cases; MCOs may interpret it as a hard stop.
• For individuals with chronic, life-long needs, it is unclear how providers will justify continued CPST beyond 12 months.

Caregiver and Crisis Requirements

• Mandating caregiver participation is unworkable for youth in foster care or without reliable caregivers.
• Inconsistencies between requiring caregiver crisis availability within 2 hours vs. mandating 24/7 agency crisis response.
• Expecting in-person crisis response is unrealistic for rural providers; referral to 988 or crisis teams should be allowed.

Exclusions and Access Risks

• CPST cannot be used if another EBP is deemed more appropriate (e.g., ACT, Clubhouse, PSR, IOP). Providers worry: What if the consumer refuses those services? What if the service is unavailable in their community?
• The design is too rigid, which risks excluding people who could benefit.

Documentation and Reauthorization Burden

• Extensive documentation requirements (demonstrating outpatient insufficiency, quarterly reviews, proving progress) will create delays and administrative overload.
• Criteria for “progress” (tool scores vs. clinical documentation of stability) are undefined and may lead to inconsistent MCO decisions.
• Risk that strict criteria will replicate current problems where MCOs interpret rules differently, creating inequities and denials.