Department of Medical Assistance Services
Board of Medical Assistance Services
General Notice: Notice of Public Comment Period: Community Psychiatric Support and Treatment (CPST)
CLOSED Opened on 6/9/2026 and Ended on 6/30/2026
View all comments
77 comments
| Comment Title | Commenter | |
|---|---|---|
| # RE: Public Comment on the Proposed Community Psychiatric Support and Treatment (CPST) Regulations | Anonymous (240697) | 7/1/26 12:00 am |
| Eligibility & Medical Necessity | Helen Holz, Compass | 6/30/26 11:59 pm |
| Service Authorizations | Helen Holz, Compass | 6/30/26 11:37 pm |
| CPST V3 comments | HopeTree Family Services | 6/30/26 9:10 pm |
| 8.4. Additional criteria for youth - parent crisis availability | Gretchen Wilhelm, VNPP | 6/30/26 9:06 pm |
| 5.3.2 B.i. Crisis Support Procedures - unrealistic, unhelpful, and risky with PHI | Gretchen Wilhelm, VNPP | 6/30/26 8:53 pm |
| Can we please see Chapter IV? | Gretchen Wilhelm, VNPP, Compass | 6/30/26 8:36 pm |
| CPST V4 Feedback | Health Connect America | 6/30/26 8:27 pm |
| Additional CPST comments | LaChondra Everett/Prince William Community Services Board (IIH) | 6/30/26 7:39 pm |
| Comments | LaChondra Everett/Prince William Community Services Board (IIH) | 6/30/26 7:22 pm |
| These changes further tax our already strained workforce | Daphne Cunningham, Hampton-Newport News CSB | 6/30/26 7:09 pm |
| Diffusion of responsibility increases potential for "fraud, waste, and abuse" | Gretchen Wilhelm, VNPP | 6/30/26 7:05 pm |
| CPST Draft Regulations | Paulette Skapars, RBHA | 6/30/26 5:01 pm |
| CPST Draft Manual Update - Public Comments | Intercept Health | 6/30/26 4:44 pm |
| Miscellaneous | Jennifer Fidura, Virginia Network of Private Providers, Inc. | 6/30/26 3:45 pm |
| unrealist | Anonymous (240667) | 6/30/26 3:22 pm |
| CPST Draft Regulation Feedback | Emily Londeree, Dominion Care | 6/30/26 3:07 pm |
| Overall comments regarding CPST | Henrico Area Mental Health and Developmental Services | 6/30/26 2:03 pm |
| Administratively Burdensome and not actually helpful to clients | AL, LCSW | 6/30/26 1:40 pm |
| Overall Comments | WTCSB | 6/30/26 1:39 pm |
| Comments on current CPST | Dr. Melba R. Moore | 6/30/26 1:33 pm |
| CANS | Anonymous (240661) | 6/30/26 12:59 pm |
| crisis support | Anonymous (240660) | 6/30/26 12:53 pm |
| Required EBP/and programs may limit access to care | Rappahannock Area CSB | 6/30/26 12:42 pm |
| CANS Lifetime | Amy Jindra, LPC, RACSB | 6/30/26 12:37 pm |
| definitions clarified pg 7 | Amy Jindra, LPC, RACSB | 6/30/26 12:34 pm |
| Medicaid Behavioral Health Redesign | Helen Leonard, Virginia resident | 6/30/26 12:33 pm |
| clubhouse/cpst director | RACSB | 6/30/26 12:32 pm |
| pg- Clinical director | RACSB | 6/30/26 12:30 pm |
| Reliance on external entities | Jennifer Fidura, Virginia Network of Private Providers, Inc. | 6/30/26 10:51 am |
| Draft and service concerns | Anonymous (240651) | 6/30/26 9:37 am |
| Likely fallout from CPST implementation | Anonymous (240650) | 6/30/26 8:45 am |
| Who benefits and who loses from CPST | Anonymous (240648) | 6/30/26 8:37 am |
| Suggested Alternatives | Rappahannock Area Community Services Board | 6/30/26 8:29 am |
| Concerns with Proprietary Training, Credentialing, and Administrative Requirements | Rappahannock Area Community Services Board | 6/30/26 8:28 am |
| CPST concerns | Anonymous (240645) | 6/30/26 8:24 am |
| Behavioral Health Technician Pathway | Rappahannock Area Community Services Board | 6/30/26 8:23 am |
| Person-Centered Care and Individual Choice | Rappahannock Area Community Services Board | 6/30/26 8:19 am |
| Training and Workforce Capacity | Rappahannock Area Community Services Board | 6/30/26 8:18 am |
| Definitions Requiring Clarification | Rappahannock Area Community Services Board | 6/30/26 8:18 am |
| Care Coordination and Managed Care Requirements | Rappahannock Area Community Services Board | 6/30/26 8:17 am |
| Evidence-Based Practice Requirements | Rappahannock Area Community Services Board | 6/30/26 8:16 am |
| Documentation and Administrative Burden | Rappahannock Area Community Services Board | 6/30/26 8:15 am |
| Assessment Requirements and Conflicts with Licensing Standards | Rappahannock Area Community Services Board | 6/30/26 8:14 am |
| Clinical Oversight, Staffing, and Supervision Requirements | Rappahannock Area Community Services Board | 6/30/26 8:13 am |
| Fiscal and Operational Feasibility | Rappahannock Area Community Services Board | 6/30/26 8:12 am |
| CPST Manual Comments | NRVCS | 6/29/26 8:41 pm |
| Typos | Abigail Roff, Impact Living Services | 6/29/26 3:48 pm |
| Practical Feedback | Impact Living Services | 6/29/26 3:47 pm |
| Areas of Draft Policy Needing Clarifying Details | Impact Living Services | 6/29/26 3:42 pm |
| Concerns with MCOs Increasing Power of Oversight with Little Protection for Providers | Impact Living Services | 6/29/26 3:31 pm |
| Manual Feedback 6-29-2026 | Heather Lewis, Elk Hill | 6/29/26 2:40 pm |
| Feedback and Clarification Needed | Circe Black, RBHA | 6/29/26 2:36 pm |
| COMMENTS | Loudoun MHSADS (CSB) | 6/29/26 2:26 pm |
| Comments and Concerns | RBHA | 6/29/26 2:23 pm |
| Concerns, suggestions, questions | Laura Davis | 6/29/26 2:12 pm |
| Peer and Community Resources | Martin Mash, Vocal Virginia | 6/29/26 11:30 am |
| Peer Support for Community Based Services | Kristine Konen | 6/29/26 7:13 am |
| 3.2.2 and 3.2.3 Excessively burdensome | Gretchen Wilhelm, VNPP | 6/27/26 9:26 pm |
| CPST Community Feedback | Anonymous (240605) | 6/27/26 11:49 am |
| Comment on Version #3 | Jennifer Fidura, Virginia Network of Private Providers, Inc. | 6/26/26 3:49 pm |
| Continued confusion in new draft | Anonymous (240602) | 6/26/26 9:58 am |
| Billing Structure | Anonymous (240601) | 6/26/26 9:52 am |
| VCOPPA Comment on V4 CPST Policy Manual | Nina Marino, Virginia Coalition of Private Provider Associations | 6/25/26 3:38 pm |
| Comments on the Revised Draft of CSC | Fairfax-Falls Church Community Services Board | 6/25/26 2:23 pm |
| 4.1.2 Appreciated with some concerns | Gretchen Wilhelm, VNPP | 6/25/26 2:16 pm |
| Another Comment on Version #3 | Jennifer Fidura, Virginia Network of Private Providers, Inc. | 6/25/26 1:24 pm |
| Service Components and Claims Data | Helen Holz, Compass | 6/25/26 11:05 am |
| CPST Regulations: Access and Workforce Impact | Jewel Kindred, LCSW -Richmond Behavioral Health Authority (RBHA) | 6/25/26 10:42 am |
| Place of Service Billing for CPST | Helen Holz, Compass | 6/25/26 9:50 am |
| Oppose | Anonymous (240588) | 6/24/26 10:49 pm |
| define modifiers/claims | Anonymous (240576) | 6/24/26 11:31 am |
| EBP Readiness Assessment- Projected Impact & Provider Transition Plan | LeVar Bowers | 6/22/26 2:41 pm |
| Comment on Version #3 | Jennifer Fidura, Virginia Network of Private Providers, Inc. | 6/19/26 11:04 am |
| Comment on Version #3 | Jennifer Fidura, Virginia Network of Private Providers, Inc. | 6/19/26 10:57 am |
| Questions/comments | Anonymous (240559) | 6/16/26 8:41 pm |
| Concerns about human rights and individualized treatment | Leigh Engle | 6/10/26 10:12 am |
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