CPST is a highly structured clinical model built on layered accountability, but it is being deployed into a workforce and service environment that cannot sustain the requirements. The CPST model as written clearly benefits certain populations and agencies while making much needed supports not feasible to provide or access for others.

1. Clients / Individuals Receiving Services
   1. Who benefits:
      1. People with clearly defined, diagnosable, moderate-to-severe needs. Especially those who: meet LON 4–6 criteria, have measurable functional impairment across domains, respond well to structured, skills-based interventions
      2. Individuals in fragmented or under-coordinated systems
      3. Youth/adults currently bouncing between providers
      4. People who respond well to skills-based, structured care
   2. Who loses (or may experience reduced benefit)
      1. Individuals needing high-containment / high-structure environments
         1. Why: CPST is not a daily structured environmental support (like some of the services it is designed to “replace”). CPST has less continuous behavioral shaping and less peer-group therapeutic programming.
      2. Individuals with inconsistent engagement or chaotic living environments (ex: homelessness, unstable caregiving, severe disorganization)
         1. Why: CPST assumes engagement capacity, availability for scheduled intervention, and caregiver participation (for youth).
      3. People in rural or underserved regions (access inequity)- not a clinical exclusion, but a practical one
         1. Why: fewer providers equals longer wait times, staffing shortages equals limited Tier 2 availability, travel constraints reduce intensity delivery
2. Providers (Agencies + Individual Clinicians)
   1. Who benefits
      1. Large, well-capitalized provider agencies (CSBs, large nonprofits)
         1. Why: Can more readily absorb training costs, have greater supervision structure, administrative systems, workforce layers, and are better positioned for compliance infrastructure
      2. Clinically structured, EBP-oriented organizations
         1. Why: Model aligns with CBT frameworks, MAP-style structured practice, measurement-based care, and reduces variability in clinical approach expectations
      3. Providers who already operate like “team-based systems”
         1. Why: CPST formally validates team-based care: LMHP = clinical lead, QMHP = service delivery coordination, BHT = skills reinforcement
   2. Who loses
      1. Small and rural agencies / independent providers
         1. Why: High fixed costs with supervision requirements, training mandates, documentation systems. Hard to maintain staffing ratios, credential diversity, coverage requirements
      2. LMHPs (especially supervisors)
         1. Why: Become system bottleneck: supervision load, oversight caps (75–120 cases), documentation review responsibility. High cognitive load: clinical + compliance + administrative oversight
      3. Frontline QMHPs/BHTs
         1. Why: High turnover environment plus heavy expectations, strict role boundaries may limit autonomy, increased task fragmentation, high training burden before full productivity
3. CSBs
   1. Who benefits
      1. CSBs with strong infrastructure and funding stability
         1. Why: Already operate multi-disciplinary teams, formal supervision structures, compliance systems, better able to align with LON-based authorization, structured service tiers
      2. CSBs with integrated crisis and outpatient systems
         1. Why: CPST complements crisis stabilization workflows, coordinated care transitions, Better continuity across service lines
   2. Who loses (or is stressed)
      1. Under-resourced or rural CSBs
         1. Why: Staffing shortages become binding constraint, difficulty maintaining MAP credentialing pipeline, supervision coverage, and Tier 2 intensity levels
      2. CSBs with older TDT-like structures
         1. Why: Must rebuild service model: from structured day programming to episodic community care, transition costs: workforce retraining, program redesign, billing system overhaul
      3. CSBs facing high demand growth
         1. Why: CPST may increase access eligibility clarity → more demand, but workforce expansion lags behind demand surge
4. Schools
   1. Who benefits
      1. Schools with strong external mental health partnerships
         1. Why: CPST formalizes coordination with clearer external provider roles, defined crisis pathways, reduces informal “who is responsible?” ambiguity
      2. Schools with students who can function in less restrictive environments
         1. Why: CPST supports in-community stabilization, less reliance on segregated therapeutic schooling models
   2. Who loses
      1. Schools that relied heavily on TDT structure for behavioral stabilization
         1. Why: TDT previously provided daily therapeutic containment, structured behavioral reinforcement, embedded school-day intervention. CPST replaces this with intermittent services, external scheduling, less consistent in-school support
      2. Special education and behavioral support teams
         1. Why: More burden shifts back to schools with behavioral stabilization, crisis management, classroom support.
      3. High-need student populations (severe emotional dysregulation, trauma-related behavioral issues, frequent crisis escalations, etc.)
         1. Why: loss of daily structured therapeutic environment, increased reliance on episodic interventions. Leads to potential increases in suspensions, crisis referrals, and absenteeism

Overall:

Primary winners: well-resourced urban CSBs, large urban provider agencies, clinically structured EBP-aligned organizations, clients who respond well to structured outpatient care

Primary losers: rural providers and CSBs, LMHP workforce, QMHP/BHT workforce, small agencies, schools relying on TDT-style daily structured support, high-acuity youth