The following summarizes feedback regarding the "Service Definitions/Critical Features" section received from our members since the draft policy was released:

Staffing Flexibility and Cost Concerns

• Overemphasis on clinicians (LMHPs) for team composition; many activities could be performed by QMHPs.
• Requiring LMHPs for all supervision (and limiting supervisees to nine) is cost-prohibitive and limits workforce capacity.

IEP and Funding Barriers

• Current IEP-related language conflicts with education rules and funding structures
• Providers cannot be written into IEPs without triggering funding obligations for schools.

Service Delivery Practicality

• The 24/7 crisis support requirement is unrealistic in school-based settings.
• Limits on office-based hours reduce flexibility during closures or testing.

Reimbursement and Workload Balance

• Expectations for extensive family and school collaboration exceed what current unit structures and reimbursement rates can reasonably support.

LMHP Workforce Shortage

• The scarcity of LMHPs, especially for in-person, school-based work, makes the supervision and staffing model unsustainable.
• Broader LMHP-type supervision should be permitted.

Implementation and Role Clarity

• Confusion around how the team model functions, how BHTs fit within it, and how coordination with IEP/school teams is expected.

Service Definition Inconsistencies

• Questions remain about overlap between CPST-School and home-based CPST services, and about the roles of non-LMHP team members in coordination and care delivery.