Thank you for the opportunity to provide comments on the CPST services and revisions.

Even with these draft changes there continues to be an over-reliance on LMHP type staff. Our rural CSB can barely find QMHPs let alone enough LMHP type individuals to support this.

If we are unable to provide these CPST services in our rural communities what happens to our individual’s who were participating in programs that allowed them to be in their least restrictive environment. We are also supposed to take away their only support systems in most cases. Some individual’s are used to be provided services up to 4+ hours per week and it is likely that without services in place or at least a tiered reduction/plan in services these individuals will decompensate and predictably end up in the hospital or having other emergency situations. Many of the individuals in our rural community participate in MHSS services. This is there only socialization and support. Due to the rural nature of our CSB, trauma in individual's lives, and just lack of ability to engage with others due to symptoms and personal reasons, taking away a service that they rely on heavily is doing them a disservice.

It states that individuals 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. This is not a realistic timeframe for individuals with serious mental illnesses. If an individual is new to a service they are still building rapport at this point.

It does not seem realistic for a QMHP to work a 40 hour week and then have to be “on-call” to provide emergency services to individuals. It is my understanding that the person who works specifically with the IND would be the one who needs to respond during an emergency. Will there be training for QMHPs for managing emergencies and learning how to handle these situations?

The transition is supposed to happen July 2026. It is already almost the end of January, yet there has been no mentioning of trainings for these services. Yes community/child services had one training however it was not even enough room to scratch the surface of individuals who will need the training. There has been no mention of when another training will occur. This deadline is quickly approaching and I fear we will not be adequately prepared for the transition.