A summary of feedback received from our members on this section follows:

Exclusions and Concurrent Services

• Draft rules prohibit CPST from being authorized alongside other services (e.g., Clubhouse, ACT, PSR, CSC, IOP, Partial Hospitalization, Community Stabilization).
• Providers strongly object, noting that services like CPST and Clubhouse are complementary, not duplicative—similar to current PSR + MHSS combinations.
• Lack of clarity on transitions between services (e.g., PSR → CPST) creates risk of gaps in care. Providers ask for grace periods and overlap allowances.

Service Settings and Office Restrictions

• Office-based services are capped at 1 hour per week per client, which is impractical for intakes, CANS completion, and clients who cannot safely be served in community settings (e.g., homelessness, unsafe neighborhoods).
• Restrictions would harm both service access and efficiency.
• Excluding summer programming risks cutting off therapeutic summer interventions for youth—clearer guidance is needed to distinguish them from recreational camps.

Crisis Services and Overlap Issues

• CPST is being expected to deliver elements of crisis support but providers are barred from billing separate crisis services.
• This is contradictory: agencies are required to do more without reimbursement.
• If clients show up for crisis services from other providers while also in CPST, agencies risk nonpayment with no clear guidance.

Billing and Workforce Restrictions

• Non-licensed staff billing cap of 504 units/month (~31.5 hrs/wk) across all employers is unworkable and creates tracking issues, especially for staff employed at multiple agencies.
• This restriction eliminates flexibility for staff to work overtime or cover high-need cases.
• Questions remain about whether DMAS/MCOs will maintain a central log or if agencies will be held responsible.

Unpaid/Non-Reimbursable Activities

• Many required tasks are not billable, including scheduling and coordination calls, paperwork and documentation without the client present, internal staff meetings and case collaboration, research and external coordination for client benefit.
• These are essential to care, yet agencies must absorb the cost while also meeting new LMHP, supervision, and availability mandates. This creates an unsustainable financial model for small and mid-sized providers.