Below is specific section-by-section feedback from our members where provided:

4. REQUIRED SERVICE OVERSIGHT AND SUPERVISION

• 4.2 – Concern about the max of 9 staff a Clinical Director can supervise. This limit should be set by the agency, not DMAS. Part-time vs. full-time staff not accounted for.
• 4.3.3 – Requirement that the Clinical Supervisor must be fully licensed is unrealistic given LMHP shortages. Residents and LMHP-types should be permitted.
• 4.3.5 – 24/7/365 LMHP availability is not appropriate for CPST, which is not a crisis service. Should be required only during operating hours.
• 4.4 – Weekly team meeting in person is impractical for community-based services over large geographies. Satellite offices would increase costs.
• 4.4 & 4.5.5 – Request evidence supporting in-person supervision requirements; telesupervision is proven effective and necessary in rural areas.
• 4.5.2 & 4.5.3 – Clarify whether requirements refer to licensure supervision vs. clinical supervision; need clarity on definition of full-time QMHP and caseload cap calculations.
• 4.6 – Staff caseload caps are unnecessary and overly complicated; should be left to agencies. Non-licensed staff capped at 31.5 billable hrs/week (504 units/month) restricts workforce flexibility.

5. REQUIRED SERVICE COMPONENTS

• 5.1–5.2 – Confusion about who can write assessments, ISPs, and quarterly reviews (LMHP vs. LMHP-type vs. QMHP). Clarify authorship vs. sign-off rules.
• 5.2.7 – Requiring all team members to attend quarterly reviews is impractical for home- and community-based services.
• 5.3.3 – Requirement for 24/7/365 crisis support is impractical and unfunded. CPST is not a crisis service; QMHP-Ts cannot provide crisis care.
• 5.4.5 – Clarify whether Restorative Life Skills Training groups can be provided in office settings or only in community/schools.
• 5.5 – QMHP-Ts cannot provide care coordination, limiting workforce unnecessarily. Nurses should be permitted.
• 5.7 – Clarify if there is a minimum number of psychotherapy hours required.
• CANS – Requirement for in-person administration is unnecessary; telehealth is effective and should be allowed. Concern about duplication with second assessments.
• Crisis Support Rules – Contradictory language: CPST expected to provide crisis services but cannot refer to 988/Mobile Crisis. Unsafe in rural areas.

6. PROVIDER QUALIFICATION REQUIREMENTS

• Provider specialty missing; unclear how agencies will align with new requirements.
• 6.3 – Accreditation deadline of January 2027 allows <6 months after CPST launch — impossible since accreditation often requires prior service delivery.
• Accreditation – External accreditation required in addition to DBHDS oversight is duplicative, costly, and prohibitive for small/mid-sized agencies.
• Costs – Accreditation, admin, and training costs are unfunded and unsustainable given low reimbursement rates.

7. CPST MEDICAL NECESSITY CRITERIA

• 7.1 – Insufficient information on CANS Lifetime tool; cannot evaluate requirement.
• 7.1.2 – Contradiction: DDs and SUDs are DSM diagnoses — clarify if MH-only diagnoses required.
• 7.1.4 – “Must demonstrate outpatient therapy insufficient” — unclear if prior therapy failure required, or clinical judgment sufficient.
• 7.2 – Caregiver participation requirement unrealistic for foster youth or children without reliable adults.
• 7.3.4b – Clarify whether consumers must “fail” Tier 1 before receiving Tier 2, or if assessor judgment suffices.
• 7.7 – Length of stay limited to 4–12 months is too short for meaningful progress; MCOs may interpret as hard stop.
• Functional Impairment Criteria – Confusing 2 vs. 3 domain thresholds; must be simplified.
• Hours by Tier – Tier 1 (4–6 hrs/month) and Tier 2 (7–28 hrs/month) far lower than legacy services (8–15 hrs/week). Not enough time for documentation, crisis, and interventions.
• Exclusion Criteria – CPST not allowed if another EBP deemed “better.” Unclear what happens if client refuses or service unavailable.
• Progress Definition – Reauthorization requires “progress,” but unclear if tool scores or clinical documentation count.

8. EXCLUSIONS AND SERVICE LIMITATIONS

• 8.2.d – CPST and Clubhouse cannot be concurrent — providers object, as services are complementary, not duplicative.
• Exclusions – No overlap allowed with ACT, Clubhouse/PSR, CSC, IOP, Community Stabilization, PHP. This creates gaps during transitions. Request grace/transition period (e.g., 30 days).
• Office-Based Limit – Only 1 hr/week allowed in office is unrealistic (intakes, safety concerns, homeless clients, unsafe communities). Waivers needed.
• Summer Programming – Risk that therapeutic summer programs could be misclassified as excluded “camps.” Needs clarification.
• Billing Limitations – QMHPs, QMHP-Ts, BHTs capped at 504 units/month. Difficult to track across agencies; no flexibility for overtime/high-need weeks.
• Non-Billable Activities – Documentation, scheduling, internal meetings, coordination not reimbursable, despite being required. Creates unfunded mandates.

9. SERVICE AUTHORIZATION

• MCO Variability – Authorizations applied inconsistently across MCOs; no retroactive authorization process.
• Initial Assessment – Undefined beyond CANS Lifetime; risks duplication.
• Timelines – One business day to submit authorization (with CANS, assessment, ISP) is unrealistic and unworkable.
• Responsibility – Unclear whether assessment agency or service provider submits authorization. Risks duplication or gaps.
• Duration – 4–12 month limit too short for chronic needs; unclear if extensions allowed.
• Unit Caps – Tier 1 (32 units/month ≈ 8 hrs), Tier 2 (112 units/month ≈ 28 hrs). No guidance on crisis overrides.
• Staff-Specific Rates – Draft lists staff-level billing codes but no reimbursement amounts. Unclear if higher-level staff paid at lower rates for lower-level tasks.
• Service Reductions – Agencies must update ISPs if MCO reduces services. Unclear if agencies may appeal reductions.

10. ADDITIONAL DOCUMENTATION REQUIREMENTS AND UTILIZATION REVIEW

• 10.4 – LMHP must review all non-licensed staff documentation every 30 days.
  • Clarify: monthly summary note sufficient, or every note requires co-signature?
  • Will EHR sign-offs count?
• Oversight Burden – Requirement for LMHPs to review/co-sign all notes is inefficient, unsustainable, and worsens burnout.
• ISPs – Must be updated every 90 days in person with LMHP/team/consumer. Clarify if “good faith effort” acceptable if client no-shows.
• Telesupervision – Limiting to 50% in-person ignores credentialed telemental health supervisors.
• Workforce Impact – LMHPs already scarce; these burdens make CPST roles unattractive compared to outpatient therapy, worsening recruitment/retention.