We support the goals of the CPST model – improving ease of access, setting standards for the quality of services and credentials of providers, and delivering services early in the course of illness.
The proposed CPST model has expanded scope beyond historical and traditional models. This draft continues with increased requirements. Of note:
Increased provider responsibilities
Expanded crisis services away from the current crisis system to crisis services to be available 24/7 within the CPST team.
Training Concerns:
The volume of training requirements is disproportionate to the provider rate and the financial burden for mandated training is generally placed on the provider. CPST providers will need additional funding, a higher rate, or a longer timeframe to complete the trainings, or a combination. However, CPST providers will need to be able to generate revenue early.
Flexibility is needed to credential children/youth-serving staff in the Managing and Adapting Practice (MAP) model. Currently the requirement is that training be completed within 18 months of hire. The MAP credentialing requires training, 6 months of consultation, and a portfolio review. It may not be possible to complete the MAP training and the other training required in the time allotted. The PracticeWise platform is the only option for MAP training. No indications have been provided regarding PracticeWise's ability to process the number of providers across Virginia who will need to be credentialed.
Provider Capacity Concerns:
The requirement for referral to EBPs, an excellent practice, will be a challenge given the lack of EBP providers in Virginia.
The requirements in the model for supervision and number of LMHPs is taxing given the behavioral health workforce shortages in Virginia.
Billing and Revenue Concerns:
The billing structure is problematic as services required under CPST share the same codes. Without clearly differentiated modifiers, there could be a significant impact to timely claims processing as well as unnecessary burdens in providing documentation demonstrating which of the activities were completed.
