Please find below our formal comments and requests for clarification regarding the proposed CPST draft policy.

1. Crisis Response Requirements (Sections 4.5 and 5.3)

We are concerned that the requirement for 24/7 LMHP access and after-hours coverage will exacerbate staff burnout and workforce shortages. Furthermore, it is unclear how providers will be reimbursed for these extended responsibilities. We request clarification on how these requirements will complement, rather than duplicate, existing Virginia crisis systems such as 988 and Mobile Crisis.

2. Psychotherapy and Service Duplication (Section 4.3)

The allowance for LMHP contacts to include psychotherapy may create overlap with existing outpatient services. We suggest more distinct language to differentiate CPST from outpatient therapy to ensure clinical appropriateness and avoid service duplication.

3. Care Coordination and MCO Involvement (Sections 3.2.3 and 5.3)

The proposed reporting expectations appear to increase administrative burdens without necessarily improving outcomes. We ask for a review of these requirements to ensure they do not exceed current authorization and utilization review processes.

4. Documentation Burden (Sections 4.3, 4.4, and Related Requirements)

The cumulative documentation, supervisory review, and tracking requirements may reduce time spent on direct service delivery. We encourage DMAS to streamline these requirements to maintain a focus on community-based support.

5. Reimbursement

Has a final reimbursement rate for CPST been established? Given the increased staffing and crisis response expectations, sustainable reimbursement is essential for provider participation.

6. Caseload Requirements (Section 4.7 and Attachment 1, Section 4)

We request clear guidance on how caseload limits will be calculated and monitored across various staff positions and service intensities.

7. MAP Dashboard Requirements

There is currently no strategy regarding the long-term management or funding of MAP resources. We require clarification on how agencies are expected to afford MAP training and account maintenance for each student.

8. LMHP-E Type

While we appreciate the extension of supervision to LMHP-E eligible staff through 2029, will there be a funding increase to support the retention of licensed staff once this provision expires?

9. Clinical Documentation Reimbursement

How will the additional hours of clinical documentation required by CPST be reimbursed? The current draft does not provide a mechanism for billing these administrative hours.

10. Service Overlap Restrictions

What is the rationale for restricting the overlap of CPST School and IIH when the treatment goals remain distinct?

11. MCO Coordination

Care coordination should remain the responsibility of the MCO. We request direct contact information for care coordinators during crises and clarification on reimbursement for the additional provider hours spent on these coordination.