Please see comments as outlined per section below:

Service Definitions:

Clinical directors requirement for in-person services creates too much strain on the workforce that is already spread too thin. Clinical directors are clinically capable of providing appropriate oversight and adherence to compliance/regulations as outlined in the service definition face-to-face via telemedicine when geographically strained and therefore, this makes more sense than an in-person requirement. This is especially true for agencies with a large geographic spread. The rate study did not justify adding additional director-level positions to satisfy geographical requirements of in-person response. As clinical directors may not be certified in the implemented EBPs for CPST (while still providing effective and ethical clinical support), in-person response to a client would not be feasible for implementation.

Additionally – the use of the world “regularly” is sprinkled throughout the sections including crisis mitigation plan updates and care coordination. A definition on what frequencies may be considered “regular” would be helpful. For some elements (i.e. crisis mitigation plans), “at least annually” would be helpful and appropriate. Whereas it would be safe to assume care coordination efforts should be more frequent.

2.1 CPST Teams:

When under the supervision on an LMHP, an LMHP-type should be able to satisfy the requirement of the LMHP in all teams. The use of LMHP-types in lieu of LMHPs (when receiving board approved supervision) is not only aligned with the Resident and Supervisee regulations, but it will significantly expand the workforce. Additionally, the rate study and planned rates for CPST did not support the LMHP oversight required per these regulations.

4.5 Crisis Consultation:

Consider allowance for an LMHP-Type (while under board approved supervision) with the same experience requirement as drafted to be available for crisis consultation. This would be particularly important for agencies utilizing an LMHP-Type to satisfy the clinical supervisor roles.

Section 5 Required Service Components:

While 3 hours a week is an improvement from previous drafts for time spent in the office, consider adding an element that permits exceptions when documented in the treatment plan and deemed clinically necessary. There are circumstances surrounding safety and health of individuals and staff (and families) that would be important to allow exceptions (communicable illness in the home, lack of privacy in the home, etc.)

5.1 CANS-Lifetime assessments:

 Telemedicine-assisted and/or telehealth should be considered and allowable to increase access to care. Rural communities with limited LMHP-Types available for in-person support are the most affected. Telemedicine-assisted with the support of QMHP/Ts providing the in-person support allow for more flexibility with the same level of assessment.

Additionally, please provide clarification on how to enroll someone who was assessed and authorized but was unable to start services. 5.1.1.a only addresses when an assessment was completed in the last 12 months by another agency. It would be assumed this also includes within the same agency as we know there are often circumstances that prevent clients from starting services as scheduled.

5.2.1 Individual Service Plan:

In bullet F. number ii – having a “brief clinical statement supporting the appropriateness” on the ISP when the explanation is already in the CANs assessment is redundant. Clinical statements would have been made already in the assessment which dictates the ISP and therefore are unnecessary on the ISP. There is also concern surrounding functionality of EHRs when adding atypical ISP elements that should be considered.

5.2.2 ISP Review and Updates:

If 90-day ISP reviews and updates are required, it should be considered to do away with quarterly progress reports.

5.3 Crisis Support:

While this outlines a more functional crisis plan than previous drafts, it should be noted that crisis support is typically initiated through telephonic only communication. Telephonic crisis intervention should be a billable element of service and consideration of a code modifier would be one effective strategy at monitoring this exception to services.

5.5 Care Coordination:

Care coordination should be a billable activity with these additional requirements. Therefore, information on how to bill telephonic care coordination should be provided.

7.1 DBHDS Requirements:

In reference to #3 regarding CAPs being shared with MCOs within 30 days. For this to be functional, there needs to be some sort of information exchange portal if these sorts of regulations continue to be put in place. This would also make sense for DMAS/DBHDS/MCOs to be able to maintain records of licensing renewals, provider enrollment codes, etc. without requiring manual input and notifications that may impact credentialing and provider networks significantly.  The increased qualifications of accreditations, etc. should support less need for this level of oversight. Increasing these administrative burdens without some sort of exchange portal for automatic notification feels excessive and may have lasting unintended effects for access to care.

8.6 Continued stay criteria:

Throughout the regulations, consider using “months” instead of days for any length of time above 30 days. This particular section references “180 calendar days” and the use of “6 months” would be a simpler way for providers to calculate progress on this level rather than counting out the days.

9.2 Admission and Concurrent Services Limitations:

While I am unsure about the reason for excluding the legacy services in the list, for the sake of potential staggered roll-out and start dates for the new services, I do not feel like psychosocial rehabilitation should be an excluded service. If that is the consideration here, it is possible that Clubhouse will roll out more slowly than CPST and therefore clients who are enrolled in PSR and plan to enroll in Clubhouse should not be penalized by engaging in a very different service that is CPST.

Section 11:

#1 – please elaborate on which documentation for non-licensed team members is required. Specifically, are we referencing clinical documents? (progress notes, ISPs, etc.) or all documents entered in the chart including administrative forms like ROIs. Consider LMHP-Types only requiring co-signatures for billable documentation and diagnostic assessments. LMHP-types under board approved supervision should have the clinical skills to be able to sign ISPs and review QMHP/T/BHT progress notes without additional oversight. Co-signature by an LMHP should only be necessary for LMHP-Types billable work and diagnostics. LMHP-Types should be able to sign off on everything else.

12.1 General Billing Requirements:

1.a – assuming care coordination and crisis can be billed phone only, please be sure to specify or include definition for “telehealth” to clarify this allowance.

Billing for the assessment has caused some confusion. You mention that both the team members (assuming an LMHP type and QMHP) can bill simultaneously for assessment and there appears to be codes per 15 minutes for assessment – does this mean that the CANs lifetime is no longer a flat rate? Is the billing going to be in addition to or only for reassessments? Consider a better explanation of the assessment billing process.

Attachment 1

1.1 MAP:

Clarify that anyone directly providing and a part of CPST teams for youth should be a certified MAP therapist. However, clinical directors that oversee services or supervise LMHP-types that are providing MAP should not necessarily require MAP therapist certification. If all those who provide MAP services must be certified through the practice wise curriculum, then a clinical director will not be training on MAP specifically and therefore should not be required to obtain certification.

3.3 Supervision:

LMHP-types and QMHP-Ts by regulation have to receive weekly supervision, but QMHPs are fully credentialled as a QMHP and therefore monthly supervision should be sufficient for this level of profession as they would have already spent 1500 hours and been receiving weekly supervision as a QMHP-T to get to that credential.

4.2 LMHP Supervision of Cases:

DMAS should adhere to DHP regulations regarding supervision qualifications including LMHP-Types to supervise QMHPs as well as QMHPs with the appropriate training to supervise QMHP-Ts and BHTs. If the LMHP type is receiving their own board approved supervision by someone in the agency, they should be more than qualified to supervise lesser credentialed staff.