The following outlines other feedback received by our members on the draft CPST-School Setting policy:

Implementation Timeline

• The timeline for implementing the new requirements is too short, leaving agencies insufficient time to prepare, train, and staff appropriately.

Workforce and Supervision Requirements

• LMHP On-Call and 1:9 supervision ratios are unrealistic, particularly for school-based or rural programs, and will intensify workforce shortages.
• The expectation for 24/7 availability contradicts the nature of school-based services and would make staffing unsustainable.
• The licensed-practitioner requirement is impractical given Virginia’s shortage of LMHPs; it risks creating a competitive “bidding war” for scarce clinicians and driving consolidation among providers which will reduce client choice and access to care.
• The rules exclude LMHP-types and QMHPs from supervisory roles, despite existing Board of Counseling regulations allowing certain supervision functions.
• Stakeholders argue for allowing licensed-eligible staff to supervise, as they already provide outpatient care, and note that excluding them undermines workforce development.

Misalignment Between Agencies and Boards

• DMAS and the Virginia Board of Counseling appear out of sync: the Board has expanded QMHP roles, while DMAS policy reverses this progress.
• The resulting inconsistency and confusion make compliance and staffing planning difficult.

Gender and Workforce Sustainability

• The expectations for 24/7 coverage disproportionately impact women in the workforce, especially younger LPCs who make up a large share of Virginia’s mental health clinicians and who often have caregiving responsibilities.
• These requirements create equity and retention concerns and threaten workforce stability.

Training and Capacity

• MAP training access remains a problem; many LMHPs have applied and been denied due to limited capacity at CEP-VA.
• Without prompt, expanded access, providers will be unable to meet required training standards before the policy’s implementation date.

Service Delivery Realities

• Office-based caps (one hour/week) and reliance on telehealth disadvantage small and rural providers and families with limited internet access.
• The policy’s expectations for year-round, in-person service and documentation add cost and workload burdens that small or rural agencies cannot absorb.

Comparative Policy Perspective

• Other states implementing CPST do not impose such restrictive, prescriptive staff requirements, highlighting Virginia’s divergence and the need for more flexibility.