Revise CPST to exclude crisis stabilization activities already covered under Appendix G and 12VAC35-105.

Clarify CPST’s role as distinct from MHSS (H0046) and IIH (H2012) as defined in Appendix H.

Amend CPST staff qualifications to include PRS and CSAC under LMHP/QMHP supervision, consistent with 12VAC35-105-20.

Adjust rates under 12VAC30-80-30 and align with the 2023 Appropriation Act Item 304 to reflect LMHP-driven team costs.

Submit CPST to CMS with boundaries clearly articulated to avoid disallowance under 42 CFR §440.130(c).

Conclusion
As currently drafted, CPST conflicts with existing services, undermines Medicaid coverage categories, excludes recognized workforce roles, and imposes unfunded mandates in violation of state and federal law. DMAS should revise CPST before implementation to ensure compliance with 12VAC35-105, 12VAC30-50-226, 12VAC30-80-30, 42 CFR §440.130(c), 42 CFR §438.12, 42 U.S.C. §1396a(a)(30)(A), and the 2023 Appropriation Act.