Lose the jargon- words that mean nothing and add nothing to understanding or delivery of services. Examples: systemic, dynamic, evidence-based, functional, etc. etc. Just say what you mean simply- the buzzwords add nothing. 

The present CPST – Youth, School Setting draft creates jurisdictional and role-boundary concerns for LMHPs overseeing care. While collaboration between behavioral health providers, families, and schools is essential, several proposed requirements appear to extend the responsibilities of LMHPs into areas governed by the educational system.

IEP/504 Role and Scope of Practice Concerns

The draft appears to require LMHPs to identify each IEP/504 goal related to behavioral, emotional, or social functioning; determine whether each goal is addressed by the IEP/504, CPST, or both; provide a clinical rationale for duplication or overlap; identify the school personnel responsible for implementing the educational component; attend an IEP/504 meeting as a condition of CPST authorization; submit clinical input to the IEP/504 team when attendance is not practicable; determine that a child’s mental health impairment adversely affects educational performance; and communicate that determination to the school team.

These requirements are problematic because an IEP/504 process is not a behavioral health treatment plan. It is an educational and legal process governed by the Virginia Department of Education and school-system procedures. While an LMHP can clinically assess whether symptoms of a mental health condition interfere with functioning, determining educational performance is not synonymous with determining clinical impairment and is part of an educational evaluation and process outside the scope of practice of an LMHP overseeing CPST care.

The proposed language stating that the LMHP “shall” attend at least one IEP or 504 team meeting per service authorization period also raises concerns. An IEP meeting is a school-governed process, and the school determines its team composition.

DBHDS regulates behavioral health services, while the Department of Education regulates the educational system. As such, CPST providers cannot establish requirements that govern how IEP/504 processes operate. CPST is distinct from educational services. Collaboration between behavioral health providers, families, and schools is an extremely important and necessary component of care; however, collaboration should not become regulatory role substitution.

Recommendation: DMAS should revise the final manual to include clear scope-of-practice language distinguishing behavioral health responsibilities from educational responsibilities. The final language should encourage LMHP participation and collaboration with schools and families when clinically appropriate, while making clear that LMHPs are not responsible for making educational determinations, directing IEP/504 processes, determining school-team composition, or otherwise assuming responsibilities governed by the educational system.

Referral to Standalone Evidence-Based Practices

Sections 3.2.1 through 3.2.3 of the CPST draft manual concerning referral to standalone EBPs create ambiguity regarding the relationship between CPST and those services.

If an EBP is clinically appropriate but unavailable, it is reasonable for a provider to document barriers to access and, when appropriate, assist the youth and family in pursuing access. However, a CPST provider cannot control the availability of a standalone EBP, geographic access, waitlists, authorization decisions made by another entity, or whether the individual and family chooses to pursue the referred services.

Being held responsible for notifying the MCO of barriers, coordinating to address access as soon as practicable, documenting all care coordination, and including a plan to transition when the EBP becomes available appears to place systemic service-access problems onto the provider that are outside of the provider’s control.

Furthermore, if an EBP is deemed clinically inappropriate, availability would not change that clinical determination. Requiring an ISP to include a plan to transition to an EBP that the assessing LMHP has determined is clinically inappropriate creates an internal inconsistency within the proposed requirements.

The treating LMHP should be responsible for assessing the youth’s behavioral health needs, determining the medical necessity and clinical appropriateness of CPST, making clinically appropriate referrals, and documenting reasonable coordination efforts. The LMHP should not be made responsible for guaranteeing access to another provider’s service or resolving systemic capacity problems.

Recommendation: DMAS should revise these provisions to distinguish between a provider’s responsibility to make clinically appropriate referrals and document reasonable care coordination efforts and the provider’s inability to control another provider’s availability, geographic access, waitlists, authorization decisions, or family choice. The final manual should also clarify that an ISP transition plan to a standalone EBP should only be required when that EBP has been determined by the treating LMHP to be clinically appropriate and indicated.

LMHP Caseload and Workload Protections

The present CPST – Youth, School Setting draft raises significant concerns regarding the expectations placed upon LMHPs.

The draft recognizes that excessive caseloads can negatively impact service delivery, staff sustainability, and client safety. It establishes explicit weighted caseload limits of 20 for staff providing the primary CPST components, including Restorative Life Skills Training, Care Coordination, and Crisis Supports. This demonstrates that the Department recognizes the importance of measurable caseload protections for staff providing direct services.

However, comparable protections are not established for LMHPs despite the significantly broader and more clinically complex responsibilities assigned to them throughout the draft.

The limits addressing clinical caseload oversight in Section 3.2 do not fully resolve this concern. These limits do not necessarily account for the additional direct clinical responsibilities an LMHP may simultaneously carry.

The distinction between caseload and workload is therefore critical. For LMHPs, who carry significant clinical, supervisory, assessment, treatment-planning, psychotherapy, and crisis-related responsibilities, there is no objective minimum standard or measurable workload methodology to ensure that an LMHP is protected from excessive assignments. This is particularly concerning given the national shortage of LMHPs.

An LMHP may simultaneously be responsible for assessments, CANS requirements, treatment planning, required 90-day contacts, psychotherapy, clinical oversight, supervision, crisis consultation, documentation, and other clinical responsibilities. A numerical limit on clinical oversight cases does not necessarily account for these additional responsibilities.

Recommendation: DMAS should establish an objective LMHP workload standard in addition to the clinical-oversight case limits in Section 3.2. The final manual should recognize that an LMHP’s total workload includes both direct clinical responsibilities and clinical oversight responsibilities and should provide a mechanism for considering clinical complexity, psychotherapy frequency, crisis activity, supervision, and other required clinical duties.

24/7/365 LMHP Crisis Consultation Requirement

The most significant concern is the requirement in Section 4.5 that each CPST provider maintain an experienced LMHP who is available for crisis consultation 24 hours per day, 7 days per week, 365 days per year.

The concern is not with ensuring that youth and families have access to appropriate crisis support. Continuous access to crisis support is important. The concern is the manner in which the proposed requirement assigns responsibility for that continuous availability to LMHPs without establishing corresponding staffing or workload protections.

The draft goes beyond simply requiring that an LMHP be available. During the instructional day, the LMHP must be reachable through an immediate and direct method and respond to a consultation request within a timeframe appropriate to an escalating in-person situation, not to exceed 15 minutes.

Outside the instructional day, including evenings, weekends, school breaks, and periods when school is not in session, the on-call LMHP must be reachable and able to respond to consultation requests within 30 minutes. Furthermore, in-person response is required when clinically necessary or indicated by the youth’s crisis mitigation plan.

An LMHP who must remain available for a 15-minute response during the instructional day cannot necessarily be treated as fully available for other clinical responsibilities during that same period. The LMHP may be conducting psychotherapy, completing an assessment, participating in treatment planning, supervising staff, traveling, or providing another clinical service.

Similarly, an LMHP who is required to remain available for a 30-minute response outside normal business hours may have significant restrictions on where they can be, what other responsibilities they can undertake, and their ability to disengage from work-related responsibilities.

The 24/7 Requirement Requires a Staffing Model

The 24/7 requirement requires a staffing model, not merely an on-call policy.

There are 168 hours in every week that must be covered. If an agency relies upon a single LMHP to provide that availability, the practical expectation would be continuous responsibility for crisis consultation in addition to the individual’s normal workweek. Such an arrangement is not a sustainable staffing model and creates obvious concerns regarding fatigue, burnout, clinical judgment, and patient safety.

Even if multiple LMHPs rotate on-call duties, the CPST agency must account for the fact that the on-call LMHP may receive an actual crisis consultation during the assigned period and that the response can involve substantially more than a telephone call.

Recommendation: The final manual should establish or clarify the staffing methodology necessary to provide reliable 24/7/365 LMHP coverage without placing an unreasonable burden on individual LMHPs. The manual should also clarify how on-call responsibilities affect an LMHP’s allowable direct-service and supervisory workload.

In-Person Crisis Response

The requirement for in-person assistance creates additional workload as well. If an LMHP is expected to be available for in-person crisis intervention, geographic coverage becomes a significant staffing consideration.

An LMHP cannot reasonably be considered available for an in-person response if that individual is providing services at another location, traveling, engaged in another crisis, conducting psychotherapy, or outside a reasonable travel radius.

Therefore, an agency’s ability to comply with the requirement depends not only on the number of LMHPs employed, but also upon their geographic distribution, schedules, existing caseloads, and availability.

Recommendation: DMAS should clarify the geographic and response-time expectations associated with in-person LMHP assistance and how agencies are expected to provide this coverage when an LMHP is already engaged in another clinical service or crisis response.

Recommended LMHP Workload Protections

The draft recognizes that caseloads should vary based on team composition, Level of Need, experience, and staff qualifications. However, that principle should be extended to LMHP workload.

DMAS should reconsider the LMHP workload provisions before finalizing the draft. At a minimum, the final manual should:

1. Establish objective LMHP workload standards in addition to the clinical-oversight case limits;

2. Establish how 24/7/365 on-call responsibilities affect an LMHP’s allowable direct-service and supervisory workload; 

3. Clarify whether an LMHP who is actively providing psychotherapy, assessment, supervision, or another clinical service can simultaneously be considered available for the required 15-minute crisis consultation response; 

4. Establish a minimum staffing expectation or staffing methodology sufficient to provide reliable 24/7/365 LMHP coverage without placing an unreasonable burden on individual LMHPs;

5. Clarify the geographic and response-time expectations associated with the requirement for in-person LMHP assistance;

6. Establish safeguards for LMHPs who have responded to significant or prolonged crises so that crisis response responsibilities do not simply become additional uncompensated workload layered on top of an already full caseload; and

7. Clarify how agencies will demonstrate during an audit that an LMHP’s total workload is clinically reasonable and does not compromise quality, safety, or continuity of care.

Conclusion

The intent of the proposed regulations—to improve access, coordination, continuity, clinical oversight, and quality of behavioral health services—is important and commendable. However, the practical ability of LMHPs to fulfill these requirements must also be considered.

The draft explicitly recognizes the need to protect other CPST staff from excessive caseloads and establishes measurable limits for those providing primary CPST components. It also establishes numerical limits for LMHP clinical oversight. However, these provisions do not adequately address the total workload of LMHPs who may simultaneously be responsible for assessment, treatment planning, psychotherapy, supervision, clinical oversight, crisis consultation, and other required functions.

Likewise, collaboration between CPST providers and schools is essential, but collaboration should not result in LMHPs assuming responsibilities that belong to educational systems. Similarly, LMHPs should be responsible for clinically appropriate referrals and reasonable care coordination but should not be held responsible for guaranteeing access to services controlled by other providers or systems.

The 24/7/365 crisis consultation requirement, including a 15-minute instructional-day response, a 30-minute after-hours response, and potential in-person assistance, represents a substantial staffing and workload obligation. These requirements should be accompanied by an appropriate staffing and workload model to ensure that LMHPs can fulfill their crisis responsibilities without compromising their other clinical obligations.

Protecting LMHPs from unsustainable workloads is not merely an employee-welfare issue. It is directly related to patient safety, quality of care, clinical judgment, workforce retention, and the ability of providers to comply with the regulations themselves.

For these reasons, it is respectfully requested that DMAS revise the final CPST – Youth, School Setting manual to establish clear role boundaries, distinguish provider responsibilities from systemic limitations, and create measurable LMHP workload and staffing protections. These revisions would support the Department’s goal of providing high-quality, accessible, and clinically appropriate services to Virginia’s youth and families while ensuring that the professionals responsible for delivering those services have the capacity to do so safely and effectively.

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.

     Thank you for allowing me to comment on the proposed revision on the Behavioral Health Redesign.  Though the new proposal is linguistically rich in verbiage and may sound good on paper, I challenge the practicality of it.  For anyone who works in public schools, it is apparent that practical solutions are needed.  The public schools need 'boots on the ground' to make a real difference.  

     Therefore, let me address some of the challenges with the current proposal.  The CPST design will reduce the number of support hours for our students in schools by 72%.  This is a drastic difference, and one that will be felt by our school systems.  Providing direct service on the front end will prevent the need for proposed services retroactively.  Our children need direct services, not the indirect services that are being proposed.

     Eliminating summer programming for students will be a big mistake!  Summer programming provides the consistency our kids need to sustain and maintain their social and emotional growth.  This has been evidenced with academics on many occasions and is no different in regard for social-emotional health and learning.  Our children and their families are excited and look forward to the summer programs each year.  For children who often do not experience extracurricular activities and community events, this piece is crucial and has a large impact in many different capacities.  It assists in teaching social skills and emotional-behavioral skills and allows children to interact with their peers in a different environment.  It also serves as a respite for families and children can take those skills back to share with their families.

    Furthermore, if you have worked in a public school system, you will realize that parent involvement isn't always optimal, as much as we would LIKE it to be.  Requiring greater parent involvement may affect an agency's ability to deliver services.  Again, we need more direct services, not indirect.

     Lastly, increasing administrative requirements often places additional burdens on staff and directly impacts the time and resources available to give back to students and families in a practical manner.  While some administrative tasks are necessary, increasing those requirements only takes away from the population you are there to serve - the students.  We need direct services and practical solutions, like TDT.   I will say again, we need 'boots on the ground' to face the challenges that students and families are facing now.  

To what degree has VDOE been engaged in the proposed changes as the new requirements will have significant limitations on the availability of staff at the school site based on the proposed allowable units per week and per month? 

The medical necessity criteria is extensive and complex – leading the service to unintentionally create barriers to access.  The layers of requirements also pose equity issues as there are multiple requirements from urban school districts and caregivers who are navigating significant and complex challenges associated high levels of economic and social needs in very high-stress environments.  In urban areas with poor social determinants of health including poverty, community violence, limited educational support and limited to no family support, students heavily rely on TDT, and will do the same for CPST, to help them be successful in the school setting.  The aforementioned challenges may require long-term supports and treatment to help them cope in their school setting. Please consider minimizing the medical necessity criteria for equitable and timely access.

Section 4 Program Oversight

Heavy reliance on LMHP staff.  There is a current workforce shortage for licensed staff in Virginia and beyond.  Please reconsider the amount of oversight and involvement requirements of LMHPs such as attendance of 504 and IEP meetings, and signing off on ISPs.

Section 5.3 Crisis Support – Requires 24/7 support be available however the rate does not support the cost to have a LMHP or QMHP on-call.  The maximum of 7-8 allowable hours (for Tier 2 if approved by the MCO) per week, will not be sufficient in an instructional setting in addition to providing crisis support that may happen in evenings, weekends and holidays. Please consider removing the requirement of 24/7 crisis support from this service OR offer more billable hours.

5.3.1.1 Preventative and Recovery Strategies

Practice and rehearsal of self-initiated crisis contact into restorative life skills training and psychotherapy requires time.  If the weekly allowable units of 8 hours per week remains, there is not sufficient time to meet with the student to engage in rehabilitative skills practice, engage in psychotherapy, meet with school personnel, attend 504 or IEP or disciplinary meetings as scheduled, meet with caregivers, respond to crises as needed, intervene when the student displays disruptive behaviors in the classroom and teach emotional regulation in vivo.  This is not possible and not sustainable for the program.  Please reconsider the allowable units for this service as the limited amount does not support a sustainable service.

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.

At a time where the needs are greater than ever you create a service that limits services to Virginians. All of the emphasis nationwide is on evidenced based services and we are attempting to make up a service that has zero evidence. I asked DMAS about the evidence and they stated there is none. We will expect these teams to be on call and serve clients in crisis as well as daily. It makes ZERO sense. 

Services in schools are needed and schools in our area rely on services to function each day but this change will take away services in our schools, again at a time where the needs are greater than ever. 

Do everyone a favor and throw this to the side, then ask the people who deliver services how to make things better. Not some academic person who has never delivered services. Virginians deserve way better than this. 

The cost of implementation is also going to limit smaller providers. To say the cost is included is absurd. 

We need to DO BETTER for our clients and our State. 

Hello, 

Public Schools are supposed to exist for ONE primary reason. 

Academic Excellence. VA has not been performing Academically 

quite so well for about 25 years overall, and in large part 

due to creep of ‘Socio-Political Programs’ and chronic Mental-Healthing 

measures like ‘Social-Emotional Learning’ - Completely Ineffective, 

with virtually, zero ROI for Taxpayers OR The Parent’s

Children. This is how they want to Trans Your Kids. Make no

Mistake about it. Just. No. 

Hello, 

School Based Services Especially If Required for FAPE 

cannot be delegated to external providers. This is known as 

Non-Delegable Duty and School Divisions across the Nation

are beginning to hemorrhage grants funding for ‘double-dipping’ 

Mental Health Services. So, just like any other Personal Physician, 

they would NOT be routine IEP Team Members which potentially 

conflicts with VACBP statements. Schools Routinely REJECT QMHPs 

and other Privately Secured Providers to control ‘the process’ as 

well as all information about any given child/ren. 

These efforts are a massive intrusion upon the families to 

conduct Psychological/Mental Health Services without a Parent/Legal Guardian present. 

Vulnerable Children with Disabilites like Autism, should NEVER be subjected to 

any questioning, studies, without express parental consent and the IDEA mandates this.

RECOMMENDATION: Cancel This Initiative. It is harmfully invasive.