The framework of the CPST proposal provides descriptions of the services; however, the translation to addressing the complexities in supporting people who experience behavioral health challenges, raises some questions.

1. CPST may only be provided by a staff who is under the authority of a DBHDS agency license.

1. Workforce Challenges and LMHP Oversight

• The proposal seems to increase the demand for Licensed Mental Health Professionals (LMHPs), based on the following excerpt from the proposal “All CPST services are to be recommended and overseen by a Licensed Mental Health Professional (LMHP) and a part of an individual service plan (ISP)”.
• Recruitment and retention of LMHPs is already a challenge to the behavioral health service system and often results in long wait times to access services. New staffing requirements may increase the difficulty in obtaining services.

• There is a statement that shows a requirement that supervisors may only be independently licensed practitioners – does this pertain to all services in the CPST proposal?

• For the Strengths Based Individual Service Planning and Monitoring: Monitoring of the individual by the LMHP-Type includes a face-to-face interaction with the individual before other service components by unlicensed team members begin. Again, if there is a workforce shortage of LMHPs, then services that can be carried out by non-licensed personnel based on proposal, will be on hold, and person cannot get the right help, right now.

2) Place of service:

• If all the services described, including counseling, can be executed in office and/ or community-based setting, this will be beneficial to many.

3) Standardized assessment tool:

• Agree with the need. Currently DLA 20 is widely used. To switch to the use of a different tool, time and money will need to be carved out to provide training on utilizing Child and Adolescent Needs and Strengths (CANS)/Adult Needs and Strengths Assessment (ANSA). This may be more of a cost than benefit in trying to improve the behavioral health support system.

4) Case Management

• Case management plays a critical role in preventing crises and supporting individuals in attaining community stability. Visits with the person in a variety of community settings is a critical piece, as well as knowing the breadth of resources available across multiple domains.

• To increase accountability and assurance that services fall within the scope of case management, require ISP to be submitted with the annual service authorization request.

5) Expanding Service Access and Availability

• The current availability of outpatient, community, and residential services is limited, with long waiting lists, creating a bottleneck in service access. The addition of services may increase the options for people, especially with the flexibility of where the services can be provided. However, the provider capacity concerns remain, and the redesign does not inherently offer solutions.

6) Addressing Needs for Care Coordination Outside Case Management

• For individuals not qualifying for case management, a service such as care coordination, may be beneficial to coordinate when someone has multiple providers such as: a combination of outpatient therapy, medication management, and primary/specialist medical care.
• It is unclear whether an LMHP or another provider would fulfill the coordination role for these individuals.

7) CPST - Integration with the 1115 SMI Waiver

• The relationship between the proposed redesign and the 1115 SMI waiver is unclear, especially regarding the integration of residential supports. How will the redesign and the 1115 SMI waiver work together to avoid duplication and ensure seamless service delivery?

8) Outreach and Engagement Reimbursement

• An important part of the continuum of supports starts with outreach and engagement, especially for individuals with Serious Mental Illness (SMI), who may be hesitant to enroll in services. Including reimbursement for outreach and engagement could help address barriers to enrollment, particularly in rural or underserved areas.

Scenario:

Person sees an independent licensed therapist and a psychiatric nurse practitioner at PCP office. Therapist and person determine that services and supports are needed to reach specified outcomes, resulting in referral to Case Management. What would be next step with new structure to assist in following areas? If referred to CPST service to address following needs, does the person have to get assessed by another LMHP that is under the CPST license?

• Obtaining and maintaining affordable housing.
• Assistance with benefit application process for Medicaid, SNAP, and social security.
• Get connected with DARS for employ support
• Connect with peer specialist
• Monitor and coordinate all supports
• Following up on medical and behavioral health appointments
• Going through court case due to multiple no trespassing charges.