A summary of other feedback provided by our members follows:

Service Design and Eligibility

• Tiers are based on staffing rather than client symptomology, which doesn’t reflect real-world needs or symptom fluctuations.
• Unit minimums (e.g., 15-minute increments) don’t allow meaningful interventions.
• The “responsible adult” admission requirement is vague and may lead to inappropriate denials, especially for youth in foster care or unstable environments.

Workforce Feasibility

• Draft assumes availability of LMHPs, but LMHPs are scarce and expensive, particularly outside metro areas.
• Restrictions such as limiting Clinical Directors to 9 staff and requiring LMHP-only assessments will create bottlenecks and shrink provider capacity.
• QMHP-Ts are underutilized, only allowed in Tier 2, which further limits workforce options.
• In-person supervision mandates (50%) are burdensome given proven telehealth alternatives.
• Concern that requirements are set up to push small and mid-sized providers out of the system.

Duration, Units, and Access

• CPST limited to 4–12 months is unrealistic for individuals with serious mental illness and chronic needs, who require ongoing support.
• Unit caps (Tier 1 = 8 hrs/month; Tier 2 = 28 hrs/month) are too low to cover consumer needs, especially in crises.
• Non-licensed staff capped at 31.5 hrs/wk eliminates flexibility for overtime and covering emergencies.
• Without emergency flex allowances, providers may have to deny care once caps are hit.

 Administrative and Training Burden

• Requirements create heavy administrative overhead, i.e., monthly LMHP review of all documentation, weekly team meetings + 4 hrs/month supervision per staff, extensive unpaid administrative tasks.
• Training mandates (MAP, CBT, CEUs, Adult Rehab Supports) are costly and difficult to sustain given high turnover in community mental health.

Exclusions and Transitions

• CPST cannot overlap with ACT, PSR/Clubhouse, IOP, etc. — but clients often need gradual transitions.
• Lack of overlap risks gaps in care; providers request transition allowance periods (e.g., 30 days).
• Office-based services capped at 1 hr/week ignores safety and feasibility issues for clients who are homeless or in unsafe environments. Waiver options are needed.

Reimbursement and Transparency

• Draft lists codes and modifiers but no reimbursement rates for LMHPs, QMHPs, or BHTs. Agencies cannot plan staffing or budgets without this information.
• Concern that reimbursement rates will not cover the intensive clinical and administrative work being required, creating an unsustainable service model.

Overall Concern

• The draft feels overcomplicated, punitive, and disconnected from service realities.
• Requirements add cost and burden without removing any existing obligations, while reducing approved client time.
• Risk: small and mid-sized agencies may close or scale back, reducing access rather than expanding it.
• Providers feel the system is being designed to look good on paper (“services are available”) while being nearly impossible to deliver in practice.