The following summarizes feedback regarding the "CPST Medical Necessity Criteria" section received from our members since the draft policy was released:

IEP/504 Plan Integration and Documentation

• Unclear whether IEP or 504 plans must include CPST goals or be submitted with service authorization requests.
• Providers are uncertain how IEP-related documentation will affect eligibility, unit allocation, and tier assignment.
• Concern that the process could create additional administrative burdens and confusion between education and Medicaid systems.

Tier Criteria and Functional Impairment Confusion

• The Tier 1 and Tier 2 criteria tied to CANS scores, diagnoses, and caregiver/school engagement are overly complex and open to interpretation by MCO reviewers.
• The Functional Impairment Criteria language is inconsistent (i.e., “must meet a and b plus one or two domains”) and needs clearer definitions for how levels determine tier eligibility.
• Lack of alignment between required family engagement (30 minutes per week) and the authorized minimum service units makes implementation impractical.
• Unclear how IEP status or impairment severity will impact tier placement and service intensity.

Family and School Engagement Requirements

• The 30-minute weekly caregiver engagement expectation may be unrealistic for many families with limited availability or competing obligations.
• School team participation is required but not well defined with unclear expectations for frequency, format, and accountability.
• The two-hour caregiver response rule for crisis consultation conflicts with the 24/7 crisis coverage expectation and may be unmanageable for families.

Service Limitations and Seasonal Gaps

• Excluding summer camp or structured summer therapy programs removes valuable continuity of care for children who rely on those supports.
• In-office service restrictions (one hour per week) are too limited to accommodate comprehensive assessments or intake needs.

Implementation and Interpretation Risks

• Ambiguous criteria for impairment, engagement, and documentation create room for inconsistent application across MCOs.
• The overall structure risks reducing service access due to administrative complexity and conflicting requirements.