Thank you for the opportunity to provide feedback at an early stage in the development process of new services. UMFS supports the inclusion of accreditation and at least one proposed evidence-based practice (EBP) for agencies providing CPST services. Additionally, we appreciate the effort to create a more standardized system of care with defined levels and intensities of treatment interventions. However, as with any well-intentioned proposal, unintended consequences could arise, potentially hindering the realization of these changes.
Specifically, it is critical to ensure that access is not restricted due to defined levels of care without clarity on how and by whom the standardized assessment tool will be implemented. For instance, while the CANS tool has been utilized for many years, its inconsistent application has led to disparities in the current locally administered CSA system. A thorough review and input from subject matter experts on CANS use at both the CSA and provider levels could provide valuable insights and lessons. The value of a standardized assessment tool can be beneficial, but the implementation process and understanding the full implications of this assessment with existing protocols is necessary to flesh out.
The current proposal lacks sufficient detail to fully understand the implications of the two levels of services being suggested and how a standard assessment tool would layer into existing protocols and EBP assessments. We encourage further opportunities for review and input as the framework becomes more fully developed and detailed.
Below is additional feedback on specific sections of the document for consideration. As always, we appreciate the opportunity for discussion to ensure the goals of these new services can reach those individuals who would benefit from high quality services and supports.
Proposed change:
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). LMHPs assess, develop ISPs, provide counseling, and monitor each individual receiving CPST, and within the structure of collaborative behavioral health services, direct the treatment and interventions provided by unlicensed staff.
The LMHP shall be responsible for monitoring and adjusting the ISP over time as goals are addressed with the eventual goal of individuals achieving recovery and titration of service volume over time to address additional needs.
High-Fidelity Wraparound does not require a LMHP to oversee this service. Adding this into the model would create barriers for access to this planning process as it’s not a clinical service and will require additional staffing at a higher salary which would need to be factored into the rate.
Proposed change:
CPST is designed to provide office-based services as well as community-based services to individuals and families who can benefit from home and/or community based rehabilitative services, including those who may have difficulty engaging in formal office settings. CPST allows for delivery of services within a variety of permissible settings including, but not limited to, office and community locations where the individual lives, works, attends school, engages in services, and/or socializes such as homes and schools. Interventions are “hands on” and task oriented, intended to achieve the identified goals or objectives as set forth in the individual’s individualized service plan. CPST Allowed Mode(s) of Delivery 1. Individual 2. Group 3. Office/on-site (including schools) 4. Off-site/community/home 5. Without Individual present
The proposed staffing structure, service settings, and delivery modes seem narrowly focused on replacing existing services, leaving unresolved questions about how current EBPs within the Medicaid benefit—such as Functional Family Therapy (FFT) and Multisystemic Therapy (MST)—would be impacted if included under the CPST framework. Additionally, introducing new models like High-Fidelity Wraparound requires a tailored approach. We recommend evaluating each model individually to align staffing requirements with the specific needs of EBP.
Regarding service delivery modes, it appears that telehealth is excluded. Telehealth is currently a critical component of FFT and Intensive Care Coordination (ICC) and removing it under CPST could present significant barriers to access. This is especially concerning families in rural areas or those facing transportation challenges. These EBPs often require the participation of specific family members to maintain fidelity, and excluding telehealth as an option may diminish families’ ability to engage fully in treatment. Additionally, eliminating telehealth may necessitate rate adjustments to account for extended travel time for providers.
We strongly recommend that telehealth remain an option for EBPs in situations where in-person participation is not feasible or at specific junctures in the intervention that do not require in-person/face to face interactions. Allowing telehealth where clinically indicated would improve access, increase family participation, and support the effectiveness of these services, particularly in areas with limited resources or logistical barriers.
Proposed change:
Standardized assessment tool for assessment and re-assessments (i.e CANS).
The proposed use of a standardized assessment tool offers valuable opportunities for improving care consistency, tracking outcomes, and enhancing data collection. However, critical questions about its implementation remain unresolved. Key concerns include determining who will conduct the assessments, how DMAS will ensure equitable and consistent application, maintaining fidelity to the assessment tools, and integrating these assessments seamlessly with existing tools required by evidence-based practices (EBPs). Without careful alignment, families may face unnecessary redundancies, completing multiple assessments that could hinder their engagement.
Historically, the introduction of standardized assessments into existing systems has, at times, unintentionally created barriers. These include reduced accessibility for families and youth, as well as administrative challenges for providers, which can compromise the effectiveness of intervention models. Misalignment with EBPs often leads to duplicated efforts and conflicting outcomes, further complicating care delivery.
To prevent these issues, it is essential to fully understand the implications of the proposed assessment tool and incorporate lessons learned from the current system. Without these considerations, the risk of creating additional barriers to access—rather than reducing them—is significant.