Staffing & Clinical Oversight
Pg. 5: The requirement that the CPST Clinical Director be available to provide in-person support at the individual’s location when clinically indicated may not be operationally feasible. A single individual cannot maintain continuous availability due to leave, illness, and competing responsibilities. The draft does not address delegation to another LMHP. Additionally, since each team tier already includes an LMHP, it is unclear why in-person involvement from the Clinical Director specifically is required.
Pg. 14: The requirement for LMHP Clinical Supervisor involvement when individuals show limited progress or lack engagement may create operational burden. Clarification is needed on thresholds for involvement and whether this expectation is scalable across caseloads.
Pg. 36: The requirement for an LMHP to either document a review every 30 days or co-sign all non-LMHP notes may be administratively burdensome. Consider clarification or flexibility in supervision expectations.
Assessment Requirements
Pg. 8: It is unclear whether the CANS Lifetime assessment replaces the CNA or is completed in addition to it. If it replaces the CNA, clarification is needed on whether it satisfies Licensing requirements, given the number of additional recommended assessments.
Pg. 12: If a CANS Lifetime completed by another DMAS provider within the past 12 months must be used, this may conflict with Licensing requirements for completion of an initial, comprehensive CNA upon admission. Clarification is needed on compliance expectations.
Pg. 12: A copy of the CANS Lifetime tool has not yet been provided for review, limiting the ability to assess feasibility and alignment with requirements.
Pg. 13: Additional information is needed regarding the length, cost, and recertification requirements for CANS training.
Pg. 30–31: The requirement to complete a CANS Lifetime for step-down determinations and monitor changes over a 90-day period raises questions about frequency of administration. Clarification is needed on how often the CANS must be completed, given the time burden of the assessment.
Service Scope & Access
Pg. 10: If services such as Assertive Community Treatment (ACT), Coordinated Specialty Care (CSC), Functional Family Therapy (FFT), or Multisystemic Therapy (MST) are indicated but not available within the CSB, referral is required. It is unclear whether sufficient provider capacity exists in the community. Questions remain regarding availability of private providers and whether CSBs will accept out-of-catchment referrals, which may create strain on larger CSBs.
Pg. 18: The requirement for care coordination by CPST team members may duplicate services already provided by Mental Health Case Managers (MHCMs), who are qualified to perform this function without needing QMHP credentials. Clarification is needed to avoid redundancy.
Pg. 36: The draft indicates that care coordination is required but may not be billable unless conducted face-to-face with the individual or caregiver. This may create financial and operational challenges.
Crisis Coverage
Training Requirements
Pg. 40: The requirement for all LMHPs/LMHP-eligible staff providing CPST Youth services to obtain MAP (Managing and Adapting Practice) credentialing within 18 months presents a substantial training burden. This includes curriculum training, six months of consultation, and portfolio review.
Pg. 41–42: Additional DBHDS and EBP training requirements for both youth and adult services are noted. Clarification is needed on overlap, sequencing, and feasibility of completing all required trainings within specified timeframes.
Compliance & Reporting
Caseload & Documentation Tracking