Questions:
Does a change in Tier require submission of a new service authorization or Continued Stay request? What is the estimated turnaround for authorization review- Could authorization approval timelines prevent a barrier to an increase in unit delivery for Tier 1 clients who demonstrate an increased need for Tier 2 level of service?
When clinically indicated, may CPST services for youth be provided concurrently in both home and school settings, and if so, how would authorization be structured?
The draft continues to reflect an increased reliance on licensed (LMHP/L-Type) staff at a time when shortages persist statewide. Requirements for in-person LMHP assessments, multi-tiered team structures, weekly team meetings, and supervision requirements will increase operational complexity and costs, potentially affecting providers’ ability to deliver CPST services.
The proposed training requirements remain extensive and are not accompanied by guidance on cost, staff time, or phased implementation. For providers already in operation, completion of required training during standard work hours will reduce ability to serve existing clients in absence of funding or rate adjustments.
Additionally, the model does not fully account for the chronic and ongoing nature of SMl. Shortened authorization timeframes, increased administrative requirements, and expanded managed care oversight may create challenges in supporting long-term stability and person-centered treatment.
Without additional clarification, funding alignment, streamlined requirements, and phased implementation, providers will struggle to comply with CPST model requirements by the anticipated 7/1/2026 implementation date and experience difficulty in sustaining ongoing operations. Continued stakeholder engagement and consideration of rate and operational adjustments are encouraged prior to finalization.