The Child and Family Services Council of the Virginia Association of Community Services Boards appreciates the opportunity to provide comment on the Draft Service definition for Community Psychiatric Support and Treatment, currently under development.

Due to the ambiguity of some of the areas that are still being developed, our first question would be on page 1, regarding Medical Necessity Criteria (MNC). Once the criteria is developed, would the LMHP assessing the client determine the appropriate MNC, or would that be determined through the Service Authorization Request?

On page 3, the initial assessment and regular re-assessment tool identified is the Child and Adolescent Needs and Strengths (CANS). The CFS Council opposes the use of this as an assessment instrument, due to the concerns that it is highly subjective and is not a clinical tool. In fact, it is often difficult for licensed professionals to navigate because it is not intended to make clinical assumptions, nor can it appropriately drive treatment recommendations, as it does not effectively capture diagnostic symptoms as they relate a child or youth’s ability to function in the core areas of their areas of daily living.

Some additional concerns regarding the CANS:

• Challenges with Navigating the CANS System: The system can be difficult to navigate, which may hinder efficient assessments.
• Adequacy for Diverse Families and Communities: There are concerns about whether the CANS system adequately addresses the needs of diverse families and communities.
• Limited Resources for Families: The system may not fully account for the limited resources available to some families.
• Data Accuracy and Accessibility: There are concerns about the accuracy and accessibility of data within the CANS system, which could lead to potential delays in intervention.

Another area of concern is that the ISP must be developed by the LMHP. We oppose that and feel like it should remain that it can be developed by a QMHP with LMHP sign- off.

With regard to agency accreditation with 24 months of licensing, the providers are in need of additional information regarding this expectation, and specifically the rationale of choosing one accreditation over another, and the purpose of such accreditation.