Pg 5 - CPST Clinical Director has to be available to provide in-person support at the individual's location when clinically needed. 1 person can't possibly be constantly available as needed...vacation, illness, other work responsibilities. Draft manual does not discuss delegation to another LMHP. At every tier, an LMHP is on the team, so it's unclear why another LMHP, who is the CPST Clinical Director, would be needed in person.
Pg 8 — It's unclear if the CANS Lifetime is replacing the CNA or in addition to the CNA. If replacing, does it meet Licensing requirements? There are so many additional assessments recommended.
Pg 10 — If the CSB doesn't provide Assertive Community Treatment, Coordinated Specialty Care, Functional Family Therapy, or Multisystemic Therapy and the service is indicated then the CSB must refer out. Will there be private providers for all these services? Are CSBs going to accept and serve out-of-catchment referrals? This might overburden larger CSBs.
Pg 11 — Requires availability of an on-call LMHP 24/7, and unclear whether this can be provided by CSB Emergency Services or must be part of CPST Team. At times, this version refers to "internal" crisis supports, which sounds like the CSB's own emergency services could be used.
Pg 12 — Has a copy of the CANS Lifetime been provided yet to be able to assess/review the tool??
Pg 12 — If a CANS Lifetime has been completed by another DMAS provider in the previous 12 months it must be used, but Licensing requires an initial and comprehensive CNA upon admission to a service. So this is either an additional assessment or won't meet Licensing.
Pg 13 — Any information on the length or cost of CANS training and recertification requirements??
Pg 14 - Requires the involvement of the LMHP Clinical Supervisor if the individual is making limited or no progress or is not engaged in order to review and update the ISP or to refer to a different service.
Pg 18 - Care coordination should be able to be provided by qualified mental health case managers who do not need to be QMHPs. Care coordination by a CPST team member is duplicative of what an MHCM can do and does.
Pg 21 — No other service is required to report DBHDS CAPs to MCOs.
Pg 30 — A CANS Lifetime is needed to step down from Tier 1 to 2, and Pg 31 refers to monitoring the individual for 90 days post step down for a worsening CANS score. So how often is a CANS done and then the length of the assessment becomes even more important.
Pg 36 requires an LMHP to write a progress note in the individual's chart every 30 calendar days to document review of documentation OR co-sign every progress note of anyone less than an LMHP.
Pg 36 seems to indicate that though care coordination is required, it's not billable unless it's F-F w/ the individual or family/caregiver.
Pg 40 requires all LMHP/LMHP-Types providing CPST Youth services to be credentialed in Managing and Adapting Practice (MAP) w/in 18 months of the agency's enrollment w/ DMAS for specialty 925. New hires have 18 mos as well. Credentialing requires curriculum training, 6 months of consultation, and a portfolio review. More training is described on pg 41 provided through DBHDS Learning Management System that must be completed w/in 12 calendar months of enrollment or new hire.
Pg 41-42 describes EBP training requirements for CPST Adults and DBHDS training.
Pg 46-47 discuss caseload limits and the need to keep an ongoing formal log of each staff's caseload to calculate an average per month over 6 month period to demonstrate compliance w/ limits.
