I appreciate the opportunity to provide feedback on the proposed Community Psychiatric Support and Treatment (CPST) regulations. As a provider of school-based mental health services, I am deeply concerned about the feasibility and impact of several provisions on access to care for youth and families. While the intent of the regulations is clear, the cumulative effect of these requirements will significantly limit service delivery in community and school settings.

• Workforce Capacity and Sustainability Concerns
  (Sections 3.3, 4,)
  Expanded training requirements, including MAP credentialing timelines and required statewide curricula, will significantly strain an already limited workforce, delay staff onboarding, and reduce the availability of qualified providers.
• Administrative and Documentation Burden
  (Sections 5.2, 3.2, 5.5)
  New requirements for EBP documentation in ISPs, extensive referral documentation, and increased care coordination expectations will substantially reduce time available for direct youth services and create barriers to timely care.
• Delays in Access Due to EBP Referral Requirements
  (Section 3.2)
  Mandating assessment and referral to standalone EBPs prior to CPST authorization—even when those services are unavailable—will delay access to urgently needed treatment and increase the risk of disengagement among youth and families.
• Concerns with CANS Lifetime as Primary Driver
  (Sections 3.1, 8)
  Reliance on the CANS Lifetime tool for eligibility, service authorization, and outcomes creates risk of inconsistent application, fails to accurately capture functional improvement, and may result in inappropriate service determinations.
• Impact on School-Based Service Delivery (TDT/SBMH)
  (Sections 2, 5, 8)
  The regulations do not adequately reflect the operational realities of school-based services, including structured school schedules, limited caregiver availability, and the need for flexible service delivery models.
• Family/Caregiver Participation Requirements
  (Sections 2, 8.1, 8.4)
  Required caregiver participation—both during sessions and on an ongoing basis—is not feasible for many working families and will create access barriers for youth most in need of services.
• Supervision and Staffing Constraints
  (Section 4)
  Supervision ratios, caseload caps, and expanded LMHP oversight responsibilities will reduce overall service capacity, slow service initiation, and increase operational costs for providers.
• 24/7 LMHP Availability Requirement
  (Section 4)
  Requiring continuous LMHP availability is misaligned with school-based service delivery models and will create unnecessary staffing burden, increased costs, and risk of provider burnout.
• Restrictions on Concurrent Services
  (Section 9.2)
  The prohibition on concurrent authorization of CPST and services such as Therapeutic Day Treatment (TDT) will disrupt continuity of care and eliminate effective, integrated school-based treatment models currently supporting students.
• Medical Necessity Criteria and School Alignment
  (Sections 8, 10)
  Highly complex eligibility, documentation, and Level of Need requirements will create confusion among school partners, hinder collaboration, and limit access for students with moderate but impactful mental health needs.
• Implementation and Financial Impact
  (Sections 7, 12)
  The scope and intensity of these requirements will significantly increase administrative, training, and staffing costs without clear alignment to reimbursement, placing financial strain on providers and risking reduced service availability.
• Need for Flexibility and School-Specific Guidance
  (Sections 2, 5, 8, 10)
  Without greater flexibility in service delivery, documentation expectations, and caregiver engagement requirements, these regulations will reduce access and undermine the effectiveness of school-based mental health services.

In conclusion, without meaningful revisions to increase flexibility, reduce administrative burden, and account for the realities of school-based service delivery, these proposed regulations will significantly reduce access to care for youth and families. I strongly encourage DMAS to further engage providers and incorporate practical adjustments to ensure these regulations are both clinically sound and operationally feasible.