I am providing feedback again today, on the draft CPST Regulations for Youth within the School-Based Setting. Overall questions and concerns in regard to CPST implementation and potential negative impact remain and are recounted below.
*The CANS Lifetime has not been released for review, nor have updates been provided in regard to its development. However, it continues to be cited within draft regulations as the primary screening tool for assessment and determining the youth’s Level of Need (LON). It is noteworthy that significant concerns continue to be expressed by Child & Family service providers who have had long-standing experience with administering the CANS as related to CSA-funded services. The CANS as it exists presently, does not support all that is listed under 3.1.1, 1-5.
*Additional Screening Tools are recommended, with 17 being listed for youth. Likewise, completing a Comprehensive Needs Assessment (CNA) appears to not be directly stated but rather implied, with the definition provided under 5.1. As such, it appears that the CANS and a CNA will BOTH be required … yes or no? If the CANS is permitted to take the place of the CNA, is there agreement with DBHDS on that? If not, can DMAS negotiate this with DBHDS?
*EBP service lines specifically recognized and reimbursed by VA-Medicaid are 4 in number, only 2 for youth, as identified in 3.2.2. While EBPs can produce optimal outcomes with model fidelity, they typically serve a niche population and do not have wide-spread application. EBPs are also expensive and cumbersome to stand up and sustain. This requirement of Referral to EBPs as outlined in Section 3.2 is a barrier to readily accessing services and will delay treatment for those youth & families most in need.
*Training requirements as delineated in Attachment 1.1 and 1.2 are extensive and burdensome. MAP training has been very limited; additionally, will resources be available to assist CPST providers with sustaining MAP relative to software and licensing costs? Likewise, the Foundational & Intermediate Skills Training and BHT Academy are seemingly not yet ready for roll-out. When will DBHDS make these be available?
*Draft regulations remain heavy in the arenas of LMHP service requirements and supervisory oversight. Not only does this create additional program burden, but it is unnecessary when there is a workforce of experienced/well-trained, Bachelors-level QMHP staff who have been composing treatment plans and delivering effective interventions in VA public schools for decades. Isn’t MAP designed to assist those providers with ‘lesser’ knowledge and skills a treatment path forward, complete with suggested goals, objectives, and interventions?
*Significant concerns surrounding financial sustainability remain, as the decreased, allowable units of CPST service simply do not support this intensive structure as presently designed. See Attachment 1, Section 4, Chart 2 for reference.
*Eligibility for CPST and the related Medical Necessity Criteria are incredibly complex and will undoubtedly pose barriers in accessing treatment, for those most at risk and most in need in our VA communities struggling with high social determinant of health! The criteria as outlined in Section 8 and the accompanying matrix in Attachment 1, Section 4, Chart 1 will present numerous opportunities for misinterpretation and CPST service denials.
