Caliber Virginia appreciates the opportunity to provide feedback on the proposed Coordinated Specialty Care (CSC) service as part of the Commonwealth’s Right Help, Right Now behavioral health redesign initiative. We support the expansion of evidence-based practices and recognize the importance of early intervention for individuals experiencing first-episode psychosis.

However, we have several concerns regarding the operational, workforce, and access-to-care implications of the proposed CSC model.

First, the staffing structure and caseload requirements present potential challenges for provider sustainability. The requirement for a multidisciplinary team, including a full-time Licensed Mental Health Professional (LMHP) Team Leader, combined with a 1:20 staffing ratio, may create barriers for many community-based providers. Recruitment and retention of licensed professionals remains a significant challenge across Virginia, and these requirements may limit the number of providers able to offer CSC services.

Second, the proposed model introduces substantial administrative and documentation requirements. These include standardized assessments such as the CANS-Lifetime tool, structured treatment planning timelines, mandatory weekly multidisciplinary team meetings, and detailed crisis planning and documentation requirements. While these elements support quality and accountability, they also significantly increase non-billable administrative responsibilities. Without corresponding reimbursement adjustments, providers may experience financial strain and reduced capacity for direct service delivery.

Third, we have concerns regarding service intensity and flexibility. The CSC model includes structured service authorization periods, unit limitations, and standardized service expectations. While consistency is important, these limitations may not adequately reflect the varying levels of acuity among individuals served. Providers must retain the ability to adjust intensity based on clinical need, particularly for individuals at higher risk of decompensation or hospitalization.

Additionally, the model places a strong emphasis on individual and family engagement. While this is a best practice, it is important to recognize that not all individuals have consistent or available natural supports. In underserved communities, barriers such as work schedules, transportation, and historical distrust of systems may limit family participation. The model should allow flexibility to ensure that individuals are not negatively impacted due to factors outside of their control.

Finally, we encourage consideration of the broader system impact. As currently structured, CSC may require significant investment in staffing, training, and compliance infrastructure. Smaller and community-based providers may face challenges meeting these requirements, which could reduce provider participation and limit access to care across certain regions.

Recommendations:

Caliber Virginia respectfully recommends the following:

• Allow flexibility in staffing models and consider alternatives to strict ratio requirements
• Align reimbursement with increased administrative and documentation expectations
• Provide flexibility in service intensity to reflect individual clinical need rather than standardized limits
• Offer phased implementation timelines to allow providers to build required teams and infrastructure
• Ensure the model accounts for variability in family and natural support engagement

Caliber Virginia remains committed to working collaboratively with DMAS to ensure that the implementation of Coordinated Specialty Care strengthens access to high-quality behavioral health services while remaining operationally sustainable for providers across the Commonwealth.