Several proposed requirements, particularly those related to encounter thresholds, in-person service expectations, billing constraints, and crisis response, do not align with CSC’s service delivery in fidelity to the evidence-based model. The CSB recommends aligning reimbursement structures with existing, fidelity-consistent service delivery approaches rather than introducing requirements that shift care toward compliance-driven models.
Implementation Timeline and System Readiness: To maintain continuity of care and fidelity to the model, a 24–36-month phased implementation timeline is recommended. Without sufficient time, providers will be forced to adopt rigid structures that are not yet operationally feasible. Several proposed requirements may not be operationally feasible within existing community service delivery systems without reducing access, increasing workforce strain, or disrupting care.
Service Intensity and Engagement Approach: Current CSC-aligned service delivery is flexible and engagement-driven, with service intensity varying by clinical need, illness phase, and individual engagement. This approach allows providers to meet individuals where they are and adjust services over time. The proposed model introduces fixed service thresholds, including minimum encounter expectations and required in-person, one-to-one contacts. These requirements do not align with the evidence-based model and may limit providers’ ability to adapt to individual needs. Aligning service expectations with flexible engagement models is critical to maintaining fidelity and effectiveness. Requirements tied to fixed service thresholds may unintentionally incentivize service delivery based on billing criteria rather than clinical need.
Billing Structure and Service Delivery: The proposed billing model introduces encounter-based thresholds and modality requirements that may influence service delivery decisions. This represents a shift away from clinically driven care toward compliance with billing requirements. The CSB recommends designing reimbursement structures that support coordinated, team-based care without imposing rigid service thresholds that conflict with clinical care.
Reimbursement Adequacy and Sustainability: If reimbursement structures do not reflect the full scope of CSC services, providers may be unable to sustain fidelity-aligned approaches. Ensuring that reimbursement covers both billable and non-billable components of care is essential for long-term sustainability.
Client Choice and Engagement: Current service delivery emphasizes client choice, enabling individuals to access services through a range of modalities and settings, including telehealth, clinic-based care, and community-based services. This flexibility is essential for maintaining engagement, particularly among youth and young adults. The proposed emphasis on in-person and one-to-one service requirements may limit this flexibility and may not align with individual preferences. Aligning CSC requirements with existing person-centered approaches will support engagement and continuity of care.
Family Engagement and Cross-System Coordination: The proposed model acknowledges the components of family involvement and coordination with schools and employment systems, but it does not fully account for the operational demands of these activities. These activities require significant time, flexibility, and coordination across systems, and these demands should be reflected in service expectations and reimbursement structures.
Age Span and Access Considerations: Rigid age criteria and limited guidance on transitions in the proposed model may restrict access or disrupt care. Aligning eligibility criteria is necessary to support continuity and clinical judgment.
Access, Waitlists, and Time Sensitivity: Early psychosis intervention is time-sensitive, and delays in access may affect long-term outcomes. System capacity limitations may lead to waitlists for CSC services. The CSB recommends setting expectations for timely access and establishing interim service pathways, including case management, outpatient services, and crisis supports, to ensure individuals receive appropriate care while awaiting CSC enrollment.
Crisis Response and System Coordination: CSC-aligned services currently coordinate with established crisis systems, including Emergency Services and Mobile Crisis. Providers support individuals during periods of instability and leverage these systems to respond to crises. The proposed requirement for CSC providers to deliver in-person crisis response before referral may conflict with the existing system design and introduce delays in accessing appropriate care. Aligning CSC with established crisis pathways will support safety and system efficiency.
Assessment Tools and Clinical Decision-Making: Current service delivery relies on clinical judgment, supported by standardized assessment tools. Although measurement-based care is important, it is integrated into a broader clinical framework. The proposed reliance on a state-specific assessment tool as the primary determinant of eligibility and service intensity represents a shift away from evidence-based practice.
Training, Supervision, and Administrative Burden: The proposed model introduces additional administrative and supervisory requirements that may increase the burden and reduce time available for direct care. Aligning these requirements with existing supervision structures will support sustainability and workforce capacity.
Documentation and Administrative Requirements: Current documentation practices support care coordination, clinical decision-making, and compliance with Medicaid requirements without being overly prescriptive. More rigid documentation requirements may increase administrative burden and divert focus from service delivery. Aligning documentation expectations with existing Medicaid requirements will support efficient and effective care.
System-Level Impact: Implementing CSC as a separate, highly structured model without alignment with existing systems may create fragmentation and strain provider capacity. Coordinating CSC implementation with current service delivery structures is essential to maintaining access and continuity of care.
The proposed model introduces requirements that do not align with evidence-based approaches and may shift service delivery toward a compliance-driven framework. Maintaining fidelity to established CSC models is essential to achieving expected clinical outcomes. The CSB recommends aligning CSC reimbursement and service expectations with fidelity-consistent practices to ensure that implementation supports, rather than disrupts, effective care delivery.