Key Concerns

1. Loss of Intensive School-Based Support TDT provides structured, therapeutic support throughout the school day, offering consistent behavioral interventions, peer interaction, and real-time skill development. The proposed CPST model offers significantly fewer service hours and relies on episodic interventions in home, school, and community settings (potentially reducing the amount of support provided in the actual school setting). This is not equivalent to the daily therapeutic environment many students currently receive and will not meet the needs of our high needs youth.

2. Increased Risk for High-Need Students Students with significant emotional dysregulation, trauma histories, behavioral challenges, and frequent crises benefit from ongoing daily support. Replacing TDT with intermittent services may result in:

• Increased behavioral incidents and crises
• More suspensions and school absences
• Greater use of emergency and hospitalization services
• Reduced academic success and school stability

3. Greater Burden on Schools Schools have relied on TDT programs to provide behavioral stabilization and therapeutic support within the educational environment. Under the proposed model, more responsibility will shift back to teachers, school counselors, special education staff, and behavioral support teams, many of whom are already stretched beyond capacity.

4. Elimination of Valuable Summer Programming Historically, TDT has provided critical summer services for vulnerable youth. These programs offer:

• Structured peer interactions
• Ongoing skill development
• Monitoring of student well-being
• Access to meals and supportive adults
• Continuity of care during school breaks

Without these services, many youth risk regression, increased behavioral concerns, and reduced access to support. Many of the families receiving TDT are unable and/or unwilling to engage in services in the home and even the community setting.

5. Workforce and Training Challenges The proposed training and credentialing requirements are extensive and dependent on external certification processes. This creates significant challenges for providers, including:

• Delayed staff onboarding and confusion amongst team members
• Reduced workforce capacity
• Increased turnover
• Greater compliance risk
• Increased financial burden

At a time when behavioral health providers are already facing workforce shortages, these requirements may further limit service availability.

6. Unclear Guidance and Duplicative Requirements Several sections of the draft create confusion rather than clarity. Examples include:

• Unclear expectations regarding the Clinical Director's role in crisis response and in-person intervention.
• Uncertainty about whether the CANS assessment replaces or supplements existing comprehensive assessments.
• Potential duplication of care coordination duties already performed through Mental Health Case Management.
• Confusing crisis requirements and expectations.

7. Implementation Concerns The transition timeline raises serious concerns for schools, providers, families, and youth. Successful implementation requires adequate training of staff and school personnel. Starting the service without the new training requirements available does not make sense. Implementing the CANs as a paper/pen method will create confusion and burdens on agencies who are required to share the document. 

8. Alignment with Educational and Special Education Requirements

Given that a significant portion of these services will be delivered in school settings and directly impact students receiving special education and behavioral supports, schools should be provided with clear guidance and training regarding the new service model before implementation.

School divisions need sufficient information to evaluate how CPST services align with existing educational requirements, behavioral intervention practices, Individualized Education Programs (IEPs), Section 504 plans, and other school-based supports. Without clear guidance, schools may face uncertainty regarding roles, responsibilities, communication expectations, service coordination, and compliance obligations.

Do the service requirements align with Virginia Department of Education (VDOE) regulations including FERPA and applicable special education laws and requirements.

9. Financial Sustainability and Service Capacity Concerns

The proposed reimbursement structure, combined with extensive staffing, training, supervision, and documentation requirements, raises serious concerns about the long-term financial viability of CPST programs.

Providers will be expected to maintain a highly trained workforce while absorbing substantial administrative and operational costs. However, the number of billable service hours available under the model may not generate sufficient revenue to sustain these requirements.

Key concerns include:

• Low reimbursement potential relative to staffing expectations.
• Extensive onboarding, certification, and ongoing training requirements that require significant time and financial investment.
• Increased supervision requirements and clinical oversight that add non-billable costs.
• Significant administrative burden related to assessments, treatment planning, documentation, outcome tracking, continued stay reviews, and compliance monitoring.
• Workforce shortages that already make recruitment and retention difficult, particularly in rural and underserved areas.

Potential impact:

• Fewer providers willing or able to offer CPST services.
• Reduced capacity and longer waitlists for children and families.
• Program closures, particularly among smaller community providers and rural agencies.
• Increased staff turnover and burnout.
• Reduced direct service time as clinicians spend more time meeting administrative requirements.

Ultimately, a service model cannot be successful if providers cannot sustain it financially. If reimbursement rates do not adequately account for staffing costs, training expenses, supervision requirements, travel time, and administrative overhead, agencies may be forced to reduce services or exit the program entirely. This would result in decreased access to care for the very children and families the model is intended to support.

We urge decision makers to reconsider implementing CPST as a direct replacement for TDT without maintaining an intensive school-based treatment option. At a minimum, stakeholders should evaluate the impacts on service intensity, student outcomes, school functioning, workforce capacity, and access to summer programming before moving forward.

Children with the most significant mental health needs deserve services that match the intensity of their challenges. Replacing a structured daily intervention with a less intensive model risks creating gaps in care that will be felt by students, families, schools, and communities alike.

Before implementation, further fiscal impact analysis should be conducted to determine whether reimbursement rates realistically support the required workforce, training, documentation, supervision, travel, and infrastructure costs.

Without adequate funding and operational support, the transition from TDT to CPST risks reducing provider participation, limiting access to services, and creating unintended consequences for students, families, schools, and communities.