The draft regulation requires psychotherapy to be billed under CPST at a lower reimbursement rate than traditional outpatient therapy. Clarification is requested regarding the intent of this requirement and why the rate would be lower?
The staffing expectations seem to require a significant increase in licensed staff. Workforce shortages will make this difficult and provide additional barriers.
The requirement for 24-hour service availability necessitates on-call staffing and compensation. Can you please explain how these rates will allow for this added staffing?
The drafted policy and procedure requirements appear to exceed what is reasonably necessary and are quite stringent.
Are the titles of staff required to be the same as in the manual in order to meet the requirements?
The regulation requires agencies to maintain a formal schedule and describe how coverage is ensured during turnover and high caseload periods. Can you please provide an example of what a “formal schedule,” looks like?
The crisis mitigation plan is new language and the requirement specifies completion within 30 days and signatures from the full team. Will an example of what this is supposed to look like be provided?
The regulation notes that MCOs may waive authorization requirements during recovery. What does this mean?
When crisis referrals occur, CPST providers are required to remain engaged. Is this duplicate billing or care coordination?
Does a tier change require new authorization submission?
The draft limits billing to 600 CPST units per month and requires monitoring of outside Medicaid billing. Does record of approved outside employment go in the personnel file?
LMHP’s cannot effectively supervise 120 cases a calendar month and complete all other duties. This would mean we would need to hire more staff or have a waitlist. Will rates cover the additional needed staff to meet the requirements? Workforce shortages will also make this difficult and provide additional barriers.
