Thank you for the opportunity to provide comments on the draft Community Psychiatric Support and Treatment (CPST) Provider Manual. We appreciate the work that has gone into developing a more standardized framework for CPST services and support the overall goals of improving service quality, expanding access to evidence-based practices (EBPs), and promoting person-centered care.

However, we have significant concerns regarding several provisions that, as currently written, may create unintended barriers to service delivery, increase administrative burden, reduce workforce flexibility, delay access to care, and create conflicts with existing licensing requirements. We respectfully request that the following issues be clarified or reconsidered before implementation.

1. Clinical Oversight, Staffing, and Supervision Requirements

Several proposed requirements appear operationally unrealistic or unnecessarily duplicative.

The requirement that the CPST Clinical Director be available to provide in-person support whenever clinically needed does not account for vacations, illness, competing responsibilities, or other routine staffing limitations. The manual does not address delegation of these responsibilities to another licensed mental health professional (LMHP), despite LMHPs already serving on every CPST team.

Additional clarification is needed regarding:

• Whether one Clinical Director may oversee both CPST and Clubhouse programs within the same agency.
• Whether 24/7 on-call LMHP coverage may be fulfilled through existing Community Services Board (CSB) Emergency Services or must be maintained solely by the CPST team.
• Whether licensed-eligible staff may participate in required on-call coverage.
• The requirement for LMHP review every 30 days or co-signature of progress notes, which creates substantial administrative burden with limited demonstrated clinical benefit.
• Increased supervision requirements for LMHP-Eligible staff, Qualified Mental Health Professionals (QMHPs), and Behavioral Health Technicians (BHTs), which remain difficult to operationalize given current workforce shortages.