1. Medical Necessity Criteria Development

• As medical necessity criteria remain “not yet developed,” we urge the state to expedite this process. Clear and transparent medical necessity criteria are vital to:
• Prevent inconsistent service authorization and delivery.
• Provide clarity for providers regarding eligibility thresholds for Level 1 and Level 2 services.

2. Staffing and Supervision Standards

• While LMHP oversight is appropriate, we recommend further clarity and specific limits for staffing and supervision to ensure quality care:

• Supervisor-to-Staff Ratios: Establish clear ratios for LMHPs overseeing unlicensed practitioners (e.g., QMHPs, QMHP-Trainees).
• Caseload Limits: Define caseload maximums for licensed and unlicensed staff to prevent staff burnout and safeguard quality.
• Supervision Requirements: Specify required hours of clinical supervision for QMHP-Trainees and CSACs on a monthly basis.

3. Accreditation Timeline

• While accreditation ensures high standards, the proposed 24-month timeline may present challenges.
• Recommendation: Extend the timeline to 36 months with interim milestones to allow agencies to prepare adequately while continuing service delivery.

4. Documentation and Quality Metrics

• The draft emphasizes ISP development and monitoring but lacks standardized guidelines for required documentation.
• Recommendations:
• Develop ISP requirements and provide examples to create clear documentation guidelines for crisis plans and progress notes.
• Define specific, measurable quality benchmarks and outcomes to monitor program performance.

5. Training and Workforce Development

• Required staff trainings (e.g., Trauma-Informed Care, Motivational Interviewing) are critical, but funding and accessibility may be barriers for smaller agencies.
• Recommendations:
• Provide state-funded training opportunities or grants for providers to meet the required training mandates.
• Create a centralized training hub to ensure consistent and equitable access to approved programs.

6. Financial and Operational Sustainability

• The requirements for accreditation, evidence-based practices, and advanced training introduce significant financial and operational burdens.
• Recommendations:
• Adjust the rate structure to reflect the cost of compliance, accreditation, and workforce development.
• Establish startup funding opportunities or technical assistance grants for smaller agencies.
• Clarify billing guidelines for concurrent services to minimize reimbursement denials.

7. Implementation of Evidence-Based Practices (EBPs)

• While embedding EBPs is crucial, smaller agencies may struggle to meet the one-year timeline due to cost and training barriers.
• Recommendations:
• Allow a phased implementation approach for EBP integration over 24 months.
• Provide guidance on selecting EBPs tailored to the populations served
• Support reliability monitoring and technical assistance to ensure successful adoption of EBPs.

8. Service Delivery for Complex Needs

• CPST services will often overlap with other specialized services (e.g., for developmental disabilities or substance use).
• Recommendation: Develop clear coordination protocols for individuals with co-occurring or complex needs to ensure integrated, non-duplicative care.