I appreciate the opportunity to provide feedback concerning the implementation of Community Psychiatric Support and Treatment (CPST).  As most of my nearly two decades of work experience has been with adults with serious mental illness, my feedback targets service provision for the SMI population.

The proposed changes place significantly greater responsibilities on LMHP- type staff versus the current systems of care for SMI population.  Expecting LMHP to provide program oversight, staff supervision, direct services, complete assessments, treatment plans and quarterly reviews, in addition to the existing obligations of service authorization requests, will require a dramatic increase in LMHP staffing.  Consequently, program salaries and related costs will also significantly increase.   Behavioral healthcare agencies currently struggle to fill vacancies in their workforce, especially for LMHP positions.  If the demand for LMHP drastically increases, as it appears to need to in order to meet the new CPST staffing demands, agencies will experience an even greater workforce shortfall.  

We will likely experience a shift in underutilizing Qualified Mental Health Professionals (QMHP).  Many QMHP have years of experience in addition to Bachelor’s degrees.  Their ability to write service plans under the direction of an LMHP and based off an assessment has already been clearly established in current CMHRS services.   Improving the use of evidence-based practices and outcome driven services, can occur with LMHP overseeing programs, completing assessments, and providing specific types of therapeutic services within their scope of practice.  However, QMHP staff can still develop service plans and quarterly updates, provide rehabilitative/restorative, and psychoeducational services, and crisis interventions all under the direction of an LMHP. 

I appreciate the introduction of Behavioral Health Technicians into the field.  I believe BHT create a great opportunity for supporting intensive, wrap around services, while implementing a needed step in the behavioral healthcare career ladder.  The draft CPST service definition states that a minimum of 2 years’ experience will be required for working with SMI/SED individuals.  Are there any opportunities for BHT to acquire 2 years of related work experience within the proposed CPST system? The two years of experience is not a current requirement for BHT professional registration.

Caseload size limits, while in theory, support quality of services, cannot meet universal standards.  Client acuity and current needs dictate providers’ time commitments. 

Under “Workplace or Instructional Setting Assistance” it appears to articulate work readiness type activities including limited components of job coaching.  Will these activities and reimbursement be impacted if clients have been referred to or receiving employment readiness/placement services from DARS or a contracted job coaching service?  Will a behavioral healthcare agency need to be contracted with DARS as an Employment Service Organization or follow any specific vocational rehabilitation/employment services models (i.e. individualized placement services, supported employment, etc.)?

How will approval for an agency’s selection or implementation of a research-based model of service delivery work?  Are there any recommended program models for serving individuals with serious mental illness?    What happens if the fidelity to a rehabilitative, EBP service model does not align with the CPST service definition?  Will DMAS identify the appropriate level based on the fidelity of the service modality? 

Service providers will need funds to provide required CPST trainings, pivot to other systems of care, train and hire new staff.  How will technical and financial support be provided?

I appreciate the efforts to develop a new system of support for some of the state’s most vulnerable individuals.  Thank you for any and all efforts to respond to the feedback regarding the CPST Draft Service Definition.