The following summarizes feedback regarding the "Required Service Components" section received from our members since the draft policy was released:

In-Person and Crisis Support Requirements

• Ambiguity around in-person crisis support: It’s unclear whether an LMHP must always be physically present or only when clinically necessary.
• Unrealistic 24/7 crisis expectations: Round-the-clock availability is incompatible with staffing limits, labor laws, and non-billable demands.
• Conflicting telehealth guidance: Some sections allow telehealth, while others require in-person intervention, creating compliance confusion, especially in rural areas or during public-health restrictions (i.e., quarantine).
• Crisis referral contradiction: Requiring in-person crisis support before referral to CATS conflicts with language permitting telehealth or client-preference options.
• Lack of clarity on billing: It’s unclear whether crisis time has a separate billing code or is drawn from a client’s authorized monthly units.

Service Delivery and Scope Issues

• CPST encompasses numerous activities, including assessment, planning, crisis response, psychotherapy, care coordination, and restorative skills, creating heavy workload and documentation requirements, much of which is non-billable.
• The mix of psychotherapy and rehabilitative services blurs boundaries with other programs, raising duplication concerns when clients already receive outpatient therapy.
• In school settings, limited instructional time and rigid schedules restrict the ability to provide all required service components, especially for lower-tier clients.
• QMHP-T involvement is marginalized, even though many agencies rely on them; proposed limits on their service hours significantly reduce capacity.
• The 504-unit monthly staff cap further constrains flexibility and coverage for school programs.

Psychotherapy and Level-of-Care Conflicts

• Requiring psychotherapy within CPST duplicates existing outpatient services and may lead to denials from insurers when clients are already engaged in therapy.
• For many high-risk clients, outpatient psychotherapy is not clinically appropriate; forcing its inclusion delays access to needed care and wastes resources.
• Lack of clarity on whether psychotherapy within CPST must be billed separately or included in authorized units adds operational risk.

Telehealth and Restorative Skill Practice

• The prohibition on conducting restorative skills training via telehealth appears inconsistent and limits flexibility for families and staff.
• Telehealth restrictions reduce the ability to adapt services to public-health or geographic constraints.

Administrative and Oversight Burdens

• Supervisors face unsustainable documentation and oversight loads, including review of hundreds of progress notes weekly, compliance with multiple oversight bodies (DMAS, DHP, accreditation), and 24/7 staff supervision.
• Combined supervision, administrative, and direct-care expectations are unmanageable for agencies with limited LMHP staff.
• The structure will divert staff time away from client services toward paperwork, compliance, and insurance appeals.

Workforce and Systemic Strain

• The new requirements reverse recent DHP efforts to address workforce shortages and make hiring and retention of qualified clinicians even harder.
• The overall design of supervision, service delivery, and crisis expectations discourages provider participation, particularly in school-based and rural settings.