Recommend phased implementation, flexible supervision and training, clarified crisis roles, streamlined documentation, flexibility in service delivery modalities consistent with client choice, and reimbursement aligned with service expectations to ensure CPST services are sustainable and accessible.
The proposed changes introduce significant operational, training, supervision, licensing, documentation, and crisis-response requirements that will require substantial system redesign. Based on this scope, the CSB estimates that full implementation would take 24–36 months after final guidance, including time to redesign staffing structures, train staff, integrate the CANS Level-of-Need tool into EHR systems, and align workflows with new service expectations. Implementation depends on finalized guidance, including the CANS scoring methodology and service definitions, prior to system build and training. Without phased implementation, providers may face reduced capacity and service disruptions.
While CSC appropriately targets early psychosis in youth and young adults, it does not fully address youth-specific service needs. Additional guidance is needed on school coordination, family engagement, and planning for transition-age youth. Rigid service and duration requirements may not align with youth engagement patterns, developmental needs, or family preferences. Incorporating flexibility to support client and family choice is critical to maintaining engagement and effective care. Clarification is also recommended to ensure coordination with youth-serving systems, including schools and crisis response pathways.
Service Intensity and Tier Structure: Although the revised draft moves away from explicit tier labeling, service intensity expectations tied to Level of Need still function as a tiered model. In particular, the expectation of 5–8 hours per week for moderate-intensity services remains operationally challenging and may not reflect clinical need, engagement patterns, or client choice. It is unclear whether these expectations are minimum weekly requirements or averages over time, creating potential audit and compliance risk. The CSB recommends clarifying expectations for service intensity, allowing flexibility based on clinical judgment, and ensuring that intensity ranges do not unintentionally reduce caseload capacity or limit access to care. The CSB also recommends narrowing the expected service intensity range or using an average rather than a fixed weekly expectation to better align with real-world service delivery and individual needs.
Caseload and Workforce Capacity: The combined requirements for supervision, documentation, service intensity, in-person service expectations, and crisis response will reduce the number of individuals each staff member can effectively serve. Without explicit caseload guidance or adjusted expectations, providers may be forced to reduce caseloads, decreasing access to care and lengthening wait times for services. Workforce shortages further compound this issue, as recruitment and retention challenges already limit staffing capacity. Additional non-billable responsibilities will require more staffing to maintain current service levels.
Financial and Operational Sustainability: Expanding supervision, documentation, training, crisis responsibilities, and expectations for in-person services introduces additional non-billable time that may not be reflected in reimbursement structures. This increases the risk that the cost of delivering CPST services will exceed reimbursement, potentially affecting provider participation and long-term sustainability.
Crisis Response Requirements and System Risk: Requiring CPST providers to deliver in-person crisis response before referral introduces significant clinical and operational risk. Delaying or limiting access to Emergency Services or Mobile Crisis may create safety concerns and conflict with established crisis systems. CPST is not designed to serve as a primary crisis response service. The CSB recommends clarifying that providers may immediately refer to Emergency Services or Mobile Crisis when clinically indicated, while continuing to provide consultation and safety planning support.
Training and Supervision: The proposed training requirements, including MAP credentialing and foundational skills training, may duplicate existing DBHDS requirements and delay onboarding. A phased approach over 24–36 months, along with recognition of equivalent training, is recommended. Supervision requirements should allow tele-supervision and team-based models to reduce administrative burden.
CANS and EHR Integration: Reliance on the CANS tool introduces additional implementation complexity. Integration with EHR systems will require the development of building, testing, training, and reporting. Providers need finalized scoring methodologies, crosswalks, and reporting expectations before implementation to avoid rework and delays. The CSB recommends pilot testing the CANS tool and associated workflows with a representative group of providers before statewide implementation to identify operational challenges, ensure consistent application, and support a smoother rollout. The CSB also recommends evaluating whether both CANS and WHODAS are necessary in all cases or whether aligning or consolidating assessment requirements could reduce duplication and improve efficiency.
Documentation and Audit Risk: Highly prescriptive documentation requirements increase the administrative burden and introduce audit and recoupment risk when they are interpreted inconsistently by providers and payers. Documentation should align with core Medicaid standards and focus on demonstrating medical necessity without unnecessary duplication.
Service Delivery Modality and Access: Rigid expectations for in-person, one-to-one service delivery may not reflect the realities of community-based care or client preferences. Some individuals may not feel comfortable receiving services at home or may prefer alternative settings or modalities. These requirements may increase travel time, reduce scheduling flexibility, and create billing risk when individuals are unavailable, hospitalized, or decline in-person services. Limiting flexibility in service modality may also reduce engagement, particularly among youth and individuals with transportation or access barriers. Greater flexibility, including appropriate use of telehealth and alignment with client choice, is recommended to support engagement, continuity of care, and access.
System-Wide Impact: These changes are occurring alongside MHCM and Clubhouse redesign efforts. If implemented simultaneously without coordination, the cumulative effect may reduce overall provider capacity and create unintended barriers to access.