I respectfully urge DMAS to reconsider moving forward with the proposed CPST School Setting model as a replacement for Therapeutic Day Treatment (TDT). While the goal of improving service quality is appreciated, the proposed model creates significant barriers to access, increases administrative burden, and reduces the amount of direct intervention available to students in need.  

One of the greatest strengths of TDT was its ability to provide timely, flexible, and consistent behavioral health support within the school environment. The proposed CPST model replaces this with extensive assessment requirements, mandatory referrals to other evidence-based programs, complex treatment planning requirements, intensive school coordination expectations, crisis planning obligations, and ongoing authorization requirements that will consume staff time that could otherwise be spent providing services to youth.  

The proposal also appears operationally unrealistic. Requirements such as annual MOUs with school divisions, participation in IEP and 504 processes, 24/7 crisis support availability, rapid LMHP response expectations, extensive care coordination, and multiple layers of supervision create a service model that many providers, particularly smaller and rural agencies, will struggle to implement successfully.  

Equally concerning is the financial structure of the proposed service. Providers are being asked to meet significantly greater staffing, training, documentation, and compliance requirements while operating under reimbursement structures that do not appear sufficient to support the level of licensed professional involvement required. At the same time, the reduction in service units compared to the historical TDT model limits the amount of direct clinical intervention students can receive. The result is a model that demands more from providers while delivering fewer direct services to youth. 

Ultimately, this proposal risks serving fewer children, reducing intervention opportunities within the school setting, and creating additional barriers to care for students whose behavioral health challenges are impacting their educational success. Early intervention works best when services are readily accessible. This draft moves in the opposite direction by creating a highly restrictive and administratively burdensome system. 

I encourage DMAS to carefully review provider concerns, reconsider the elimination of TDT, and work collaboratively with stakeholders to develop a school-based service model that is clinically effective, financially sustainable, and realistically implementable across Virginia schools.