Peaceable Life Therapeutic Services, Inc would like to submit the following comments for feedback to the proposed CPST services.

As a Licensed Professional Counselor working with children of all ages and adults with complex behavioral health needs, often co-occurring with neurodevelopmental needs as well, I would be very excited to have comprehensive services to refer people I support. I welcome the opportunity to work alongside DMAS and other providers to accomplish this goal.

Please consider these comments below as you continue forward with service development for CPST:

• PROVIDER AVAILABILITY
  Is the goal, along with enhancing comprehensive service structure, to increase provider availability? Because if this is part of the goal, we have several things that prevent growth of providers who take Medicaid:
  
  1) credentialling issues with insurances including Medicare and all Medicaid providers
  2) complex billing, error tracking, appealing, and remit processes
  3) timely reimbursement of claims
  4) time-extensive “non-billable” services such as research, treatment planning, collaboration with other supports in place for the individual
  5) reimbursement rates that are well below market rates for behavioral health services and that do not reflect increased cost of living expenses for providers
  
  These challenges are causing providers to leave Medicaid and Medicare billing and transition to private pay. We are already actively losing skilled providers, how is CPST going to attract providers to stay in the service, continue to bill through Medicaid, and continue to serve within a managed care structure?
  
  CPST will need to address these issues as it is developed. Currently there are limited providers of behavior health services across the state that will be willing to provide Medicaid billable services, especially small providers who cannot afford the cost of administrative and billing specialists to understand and navigate the complex billing process. The cost to provide the services often exceed the receivables.
  
  
• CLARITY OF SERVICE
  There are several criteria which state they are in development or do not have clear definitions:
  
  - Medical Necessity: who will determine medical necessity? As an LPC, we can refer to some services, but other services or assessments require a PCP? How many professionals will need to be involved to make referrals to CPST? Will those providers feel equally competent to make those referrals? Will the assessment criteria capture all of the destabilizing factors? The vagueness is concerning as well as the concern of there being complicated referral and access processes.
  
  - Measure-Based Care: Will eligibility and service be driven by scores? Will services be pulled based on improved scores when the services are the stabilization that assure the improved scores? What about individuals who are not accurately reflected in scoring assessments? Though we fully support evidence based care, providers are often bogged down by justifications and documentation that "show our work" so to speak, demand our time, but do not necessarily contribute to the services the person is receiving.
  
  - Staffing: The professional staffing lists are only part of the staff that is required to be able to operate CPST as we are understanding it. The cost of the professional staff as well as support staff, Quality Assurance and Quality Improvement, Risk Management, etc, will need to be reflected in the billing.
  
  - Accreditation: That is a huge cost! Again, going back to PROVIDER AVAILABILITY, if we are going to try to attract providers to this service and all of the red tape and complexities that it will entail, we cannot also throw a requirement to be accredited. Perhaps an incentive for accredited providers?

Thank you for your consideration.