In 3.2.2, The statement: “Prior to authorization of CPST services . . . individuals must be assessed for and referred to any clinically appropriate standalone EBP for which they meet admission criteria, regardless of whether the agency completing the CANS Lifetime offers the EBP" turns private providers into veritable VICAP assessors of days gone by and represents a very time-consuming, non-reimbursed burden for providers who are not experts in the admission and exclusion criteria for each stand-alone EBP. Will there be yet another assessment developed for this purpose?

In section 3.2.3, the provider is charged with several more administratively burdensome tasks to include documentation; care coordination with the MCO; continued, on-going efforts to seek the standalone EBP; documentation of said efforts; and additions to the ISP to include the plan to discharge and refer the client to that EBP if and when it becomes available. Fortunately, the regulations state that a plan to transition will be made "if . . . clinically appropriate" because it would not, of course, ever be clinically appropriate to discharge and refer any client who was making sufficient progress with their current services. And, if the clinicians were successfully building trust and safety with the client (reflected in the research to be strongly correlated with treatment outcomes), ending services in favor of a standalone EBP would likely result in harmful loss for the client, interfering with our duty to uphold standards of  beneficence and nonmaleficence. Therefore, the provider should only be expected to seek the availability of a standalone EBP if and when the current services are either unsuccessful and/or insufficient, wherein a referral is always warranted.