The CPST draft describes the service as including “assessment, counseling, therapeutic interventions, care coordination, crisis and functional supports.” This language directly overlaps with Appendix G, Comprehensive Crisis Services, which defines crisis as “a behavioral health crisis…in which an individual is at risk of hurting themselves or others and/or the symptoms prevent the individual from being able to care for themselves or function effectively in the community.”

Under 12VAC35-105-1860 and 12VAC35-105-1870, DBHDS requires crisis providers to complete safety plans, crisis ISPs, and documentation standards. CPST’s inclusion of “crisis supports” risks duplicating licensed crisis functions and conflicting with the statutory responsibilities of Community Services Boards under Virginia Code §37.2-500 and §37.2-601.