The proposed CPST model requires two or more team members and mandates LMHP oversight for all service components. This staffing model is financially unsustainable for many community-based providers for several reasons:

Higher Labor Costs Without Rate Parity

LMHPs command significantly higher salaries than QMHPs, PRS, or CSACs. Current reimbursement rates for rehabilitative services such as MHSS (H0046) and IIH (H2012) were not designed to cover LMHP-driven staffing.

For example, under the 2023 Appropriation Act (Item 304.VVVV.1 and 304.VVVV.2), rates were only increased by 10 percent. That modest increase does not offset the cost of building LMHP-led teams. Providers will have to absorb the difference in labor costs, creating financial strain.

Workforce Displacement

CPST, as written, excludes PRS and CSAC staff from eligibility. Providers who have invested in recruiting and training PRS/CSACs will no longer be able to bill for their services under CPST.

This creates a perverse incentive for agencies to replace lower-cost, recovery-oriented staff with higher-cost LMHPs, raising operating costs while simultaneously reducing employment opportunities for paraprofessional staff.

Destabilization of Existing Services

If payers begin authorizing CPST in place of MHSS or IIH, providers who have built entire programs around QMHPs will lose sustainable revenue streams. Many small and mid-sized agencies, particularly minority- and women-owned businesses, will not be able to survive the transition.

The result is a contraction of provider networks, leaving fewer providers to meet demand. This is in direct conflict with 42 U.S.C. §1396a(a)(30)(A), which requires states to maintain reimbursement levels sufficient to ensure access to care.

Administrative Burden and Compliance Costs

CPST requires “measurement-based care,” including the CANS Lifetime every 12 months and other standardized clinical tools. While clinically beneficial, these requirements add uncompensated administrative time, further reducing the net reimbursement rate.

Smaller providers without EHR integration or data systems will face additional out-of-pocket costs to remain compliant.

Impact on Staff Retention

QMHPs, PRS, and CSACs are the backbone of community-based services. By limiting their billable role under CPST, DMAS risks driving these staff out of the field due to lack of upward mobility and reduced utilization.

Providers will struggle to recruit and retain LMHPs in sufficient numbers, especially in rural and underserved areas where LMHP shortages already exist. This workforce gap will directly harm service availability.

Summary of Financial Effects

Providers will face increased payroll costs with no corresponding increase in rates.

PRS and CSAC staff may lose employment opportunities, reducing workforce diversity and recovery orientation.

Small and mid-sized agencies may close or downsize, shrinking Virginia’s provider network.

Administrative requirements will add uncompensated overhead, lowering sustainability.

Workforce shortages will worsen as QMHPs, PRS, and CSACs are marginalized while LMHP demand increases beyond supply.