The CPST draft emphasizes “restoring functional skills of daily living, building natural supports, and achieving identified person-centered goals.” Mental Health Skill-Building, as defined in Appendix H (updated 11/15/2024), requires “training in functional skills and appropriate behavior related to the individual’s health and safety, activities of daily living, and use of community resources.”

Under 12VAC30-50-130 and 12VAC30-50-226, MHSS is already an approved rehabilitative service within Virginia’s Medicaid State Plan. If CPST is implemented with nearly identical functional rehabilitation language, it risks redundancy in violation of federal Medicaid standards, specifically 42 CFR §440.130(c), which requires that optional rehabilitative services not duplicate existing State Plan services.