Due to the provision in Appendix G prohibiting CPST providers from providing any crisis services would carve all CSBs out of CPST. In our area, private providers do very little mental health skill building under the current regulations so there would be little to no CPST available in our catchment area if this prohibition stands.
This revision continues to exclude CPST recipients from Clubhouse services, MHIOP, community stabilization and ARTS services. It is unrealistic to expect CPST to offer all the elements of this array of services within CPST, particularly given the very short duration of CPST services expected in this version of the manual.
The expected duration of services (3-12 months) does not reflect an understanding of the challenges individuals with serious mental illness face nor a realistic timeline around recovery for this population. Also, explicitly states that MCOs have broad latitude for determining medical necessity. MCOs have demonstrated that these decisions are made with cost saving, rather than member clinical needs, as the guiding principle.
The new section in this draft requiring case coordination is totally duplicative of Targeted Case Management.
Currently an individual receiving psychosocial rehab, skill building, and therapy (2x month) at most receives 162 hours of support a month. By new unit maximums the most acute individual will receive just 28 hours a month. The reduction in resources equates to a loss of nearly 87% or 134 hours of care. Such a drastic cut in services will create undue hardships and significantly increase risks for hospitalizations. Current services divert individuals from hospitalization and incarceration. We anticipate an uptick in psychiatric crises.
The reimbursement rate and any potential service unit limitations are not likely to support the cost of 24/7 availability of F:F crisis supports by the CPST provider. Moreover, there is a requirement that if referred to a higher level of crisis services in Appendix G, the CPST provider must remain involved in the services. There is no clarity provided on if the two services can be billed concurrently, if not what potential risk is there to the crisis services provider (i.e. a CRC) to be denied payment due to the billing of CPST and/or the CPST providers failure to remain involved in the care. What responsibility do crisis service providers have to verify if there is a CPST provider involved with the individual and attempt to reach them and include them in the crisis interventions?
Must demonstrate that OPT was insufficient and don’t know how we’d do that without unnecessarily delaying the start of CPST just to show that OPT “failed.” An uptick in hospitalizations will occur while people have to move through these steps to prove they need it.
Must show “significant improvement within 90 days” or ISP must be rewritten also seems like authorizations happen every 90 days so service would likely not be reauthorized. As above this is not a realistic timeframe for individuals with serious mental illnesses.
Continued concern that everything hinges on CANS lifetime which is only tested for ages 5-21 for children/adolescents with serious emotional disorders. This tool was not designed to assess adults with serious mental illnesses nor does it include categories relevant to adults. Also, the training for the current CANS is quite lengthy and has be renewed annually creating substantial administrative burden.
The team constitutions across the tiers continues to be far too heavy on licensed providers which has an impact on cost of services and ability to provide CPST due to ongoing, severe workforce shortages for licensed staff particularly in 24-7 programs.
QMHP staff are referred to throughout the document as paraprofessionals which misrepresents the required education and experience required for this certification, which has only become more onerous in the last revision of QMHP requirements. The supervision requirements for QMHPs does not account for or respect the many years of experience many QMHPs working in the field already have.
Many pieces of the CPST requirements read as duplicative of ACT creating confusion about where CPST sits on the service continuum. If designed to be less intensive than ACT (as skill building currently) is the 24-7 crisis elements and requirements to provide day programming, OPT/IOP and crisis services seems more intensive than ACT without commiserate billing rates.
