Section 8: Exclusions and Service Limitations

• • Restrictions on Service Overlap: Prohibiting CPST for individuals eligible for other EBPs (e.g., MST, ACT) limits flexibility in treatment planning and may hinder continuity of care.
• Billing Limitations: Capping non-licensed staff at 504 CPST units per month across all agencies will constrain service delivery and impact quality of care, as it is not person-centered and doesn’t take into account individual acuity.

Section 9: Service Authorization

• • Stringent Authorization Timelines: Requiring preservice authorization within one business day of admission may be difficult to consistently meet, especially during high-volume periods.
• Complex Authorization Criteria: Mandating multiple documentation elements (CANS, ISP, engagement metrics) for service requests increases administrative burden and will delay service initiation.

Section 10: Documentation and Utilization Review

• LMHP Documentation Review: Mandating LMHP review of non-licensed staff documentation every 30 days increases supervisory demands.

Section 11: Billing Requirements

Complex Modifier Use: The requirement for precise procedure codes and modifiers based on staff type and service component increases the risk of billing errors and administrative challenges.