1. Crisis Response: Per the manual, crisis services should be available 24/7.

This service is specifically provided by the CSBs and crisis response services. It will be difficult to cross train staff for crisis response, MAP and evidenced based programming. In addition, with a shortage of LMHPs in Virginia, there are many other jobs that pay more than the reimbursement of this service will allow providers to pay that do not require being available for crisis response 24/7. Currently, for most of our licensed staff in TDT, the benefit of a daytime, school calendar schedule balances the lower salary compared to other positions. Adding a 24/7 availability requirement without a significant salary increase will outweigh the schedule benefit, and we anticipate losing them to private practice and other jobs.

Most providers will need to implement a rotating on-call system so that staff can schedule their evening/overnight/early morning hours to allow for crisis calls that will require privacy and potential access to the client’s electronic medical record (e.g. NOT running errands, watching children’s sports events, dropping them at daycare,  or eating out with friends in a restaurant). This then defeats the purpose of having the client’s regular service provider available in a crisis – odds are they won’t be connected to the regular service provider but be speaking with someone they are unfamiliar.

2. The 9:1 ratio of LMHP to QMHP while requiring a team response teams means that the LMHP may be responsible for providing services for 180 clients as QMHP max caseload is 20. This is an issue on several fronts.

1.      LMHP-E staff could be utilized in a similar role to assist in providing the team services

2.      The LMHP is billing for time under the CPST program that could otherwise be billed as outpatient taking away from CPST services

3.      The lack of LMHPs across the state places burdens on agencies that are already facing hiring and retention obstacles

3. There is not a long term plan for providers to access MAP. Once staff have been trained and completed the required hours, how do they maintain access to the online program? Providers should know the long term costs that may be required for this program.
4. The billing system is complicated and micromanaged. There is a limit on caseload, number of units per month, etc. while not accounting for multiple billers, crisis intervention, etc. Why is CPST unable to adopt a billing system similar to outpatient services to simplify things?
5. The program encourages a person-centered and trauma informed approach, however, restricts children and adolescents if the family is not involved. This could make the service restrictive to those populations (incarcerated parents, caregivers with substance abuse concerns, etc.) most in need.
6. While this program is presented as a school-based service, some of the clinical requirements focus on intensive therapy that should not take place at school. For example, family therapy, EMDR and other traumas (sexual abuse, physical abuse, etc.) are best addressed in an outpatient setting and clients should be able to receive support at school and through outpatient services. Recovery should be able to take place in multiple settings.
7. The CANS Lifetime Assessment is still under development. Providers will need to know what, if any, costs will be associated with the initial training to use the assessment, the annual retraining cost, and the time for these trainings as the cost to pay staff for training hours (which likely will not be billable) and any training fees will need to be factored into a provider’s assessment of the cost to provide the service versus payment rates.

8. What is the definition of specialized services? Section 8, p 21

Our organization has been very impressed with the roll out of MAP and the state facilitated trainings. We are very excited about moving away from the unit system and the current authorization process with the MCOs. We appreciate your time in hearing our questions and concerns regarding the daily implementation of the services.