2. Mandatory Reassessment and Referral to Standalone Evidence-Based Practices After 18 Months 

The draft requires reassessment and referral consideration for certain standalone evidence-based practices when an individual remains at the same Level of Need for 18 months. 

We support the goal of ensuring individuals have access to the most appropriate services. However, a mandatory referral process based solely on the passage of time may be overly prescriptive. 

We also note concern with the requirement that when an individual meets criterion for a standalone EBP, but cannot access it due to unavailability, inappropriateness, prior attempt and insufficient response, or achievement of maximum benefit, the provider must notify the individual’s MCO of the barrier and coordinate to address access.  While we support the intent to ensure timely access to appropriate services, the draft does not clearly differentiate how these distinct circumstances should be operationalized as “barrers” for reporting purposes, not does it define the specific coordination expectations or outcomes required of MCOs once notified.  As a result, the requirement may lead to inconsistent interpretation across providers and plans, variability in documentation standards, and uncertainty regarding whether notification is intended to trigger specific MCO action. Further clarification is needed to ensure this process is applied consistently and effectively supports access to care without creating duplicative documentation or administrative burden.  

An individual may remain at the same Level of Need while demonstrating meaningful progress, reduced crisis utilization, increased stability, stronger natural supports, and continued benefit from CPST services. In these situations, a mandatory referral process may not add clinical value. 

We recommend replacing the referral requirement with a clinical review requirement, such as: 

"Providers shall evaluate whether additional evidence-based interventions or alternative services would be beneficial when an individual remains at the same Level of Need for 18 months." 

This approach maintains accountability while preserving professional clinical judgment. 

3. Family Participation Requirements for Youth 

The draft establishes minimum caregiver participation expectations for youth receiving CPST services. 

We strongly support family engagement whenever possible. However, many youth who meet criteria for CPST experience significant family instability, including foster care placements, kinship placements, DSS involvement, caregiver behavioral health challenges, transportation barriers, and other circumstances that may limit participation. 

Requiring specific caregiver participation thresholds may unintentionally create barriers to service access for the youth who need services most. 

We recommend focusing on provider efforts rather than caregiver compliance. Suggested language could include: 

"Providers shall demonstrate ongoing efforts to engage caregivers and natural supports consistent with the youth's clinical needs and family circumstances." 

This approach promotes family involvement while recognizing the realities faced by many high-risk youth and families. 

4. The draft appropriately emphasizes that CPST providers should utilize their own crisis intervention resources before referring individuals to external crisis services. However, we respectfully request additional clarification regarding the interaction between CPST and Mobile Crisis Response (MCR), particularly for MCR providers who may be dispatched by the Regional Hub for a client enrolled in CPST with the same provider.  

The draft states that CPST providers shall not provide Mobile Crisis Response services to individuals currently receiving CPST from the same provider. We request clarification regarding how providers should respond if their Mobile Crisis Response team is dispatched through the regional call center to one of their own CPST participants. 

Specifically, we request guidance on the following operational questions: 

• If a CPST participant is dispatched to the provider's own Mobile Crisis Response team, should the provider decline the dispatch and request reassignment to another MCR provider, or may the Mobile Crisis Response team respond under these circumstances? 

• During a Mobile Crisis Response episode, should CPST services be suspended, temporarily discharged, or continue concurrently? 

• If CPST services continue during the Mobile Crisis Response episode, what activities are expected of the CPST team (e.g., care coordination, participation in transition planning, communication with the Mobile Crisis Response team)? 

• Are care coordination and continuity-of-care activities performed by the CPST team during an active Mobile Crisis Response episode considered billable CPST activities? 

• Following resolution of the crisis episode, what are the expectations for transitioning back to CPST services, including required documentation, reassessment, and updates to the Individual Service Plan or Crisis Mitigation Plan? 

We also request that DMAS include explicit policy language clarifying that: 

• CPST is not a replacement for emergency services, including 911, 988, Mobile Crisis Response, or other urgent emergency interventions.  Individuals retain the right to contact those services directly at any time when they believe there is an immediate risk and that decision shall not be discouraged.  

• Providers are not liable for delays in response when individuals independently choose to contact 911, 988, or other emergency services outside the CPST provider’s control or prior to CPST intervention.  

Additional clarification is requested regarding billing expectations associated with the required activities outlines in the section concerning external crisis support.  The draft requires CPST providers to remain actively engaged, coordinate with the receiving entity/provider, share ISP and crisis plans, notify the MCO, and complete follow up and documentation activities.  While these are appropriate care coordination and continuity of care expectations, the draft does not specify whether, and under what circumstance, these activities are considered separately billable CPST services (care coordination, crisis support, or non-billable required administrative activities).   

We are requesting clarification on how billing should be handled when: 

• Multiple crisis-related activities occur within a single episode (coordination, documentation and follow-up) 

• Services are provided across different settings or modalities 

• The CPST team remains engaged during the external crisis intervention initiated by the provider or individual.  

Clarification of these operational scenarios will promote consistent implementation across providers, reduce confusion during crisis situations, and help ensure continuity of care without creating uncertainty regarding billing, service coordination responsibilities, or duplication of services. 

5. The draft requires supervision documentation to be maintained within personnel records. We respectfully request reconsideration of this requirement or clarification regarding its intent. 

Requiring supervision documentation to be maintained within personnel records may inadvertently conflict with established human resources policies, quality improvement practices, and organizational confidentiality protections. 

We respectfully recommend allowing providers flexibility regarding the location of supervision records, provided the records are maintained securely, readily available for review, and demonstrate compliance with applicable supervision requirements. The manual should focus on the required content of supervision documentation rather than prescribing where those records must be maintained. 

6. Telehealth v In-Person Requirements for Restorative Life and Rehabilitative Skills Training 

While we support the intent of the draft to ensure CPST services are delivered in ways that promote real-world skill building and meaningful engagement, we are concerned that the proposed limits on telehealth, specifically requiring at least 50% of restorative life skills be delivered in person and limiting rehabilitation skills practice to in-person only, may create access challenges for some individuals.  

We recommend that DMAS build in additional flexibility to allow telehealth beyond the proposed limit when it is clinically appropriate and when in-person services are not feasible due to documented barriers.  We also recommend clearly defining any exceptions such as weather or safety concerns, so providers have consistent guidance on when telehealth may be appropriate.  

We request clarification on the following:  

• Whether DMAS has evaluated the potential impact of these in-person requirements on access, particularly in rural and underserved areas.  

• Whether exceptions will be permitted, documented clinical, geographic, or environmental barriers.  

Providing clear, consistent guidance will help ensure these requirements support both quality of care and equitable access.  

7. Provider Qualification Requirements (DBHDS CAPs) 

We request clarification and additional operational guidance regarding the requirement that “DBHDS Corrective Action Plans shall be communicated to MCOs by the provider within 30 calendar days.” Specifically, we recommend DMAS or DBHDS clarify what types of corrective action plans must be reported (ex. Formal DBHDS enforcement actions versus informal plans or technical assistance), and whether the 30-day timeline begins from issuance, receipt, or finalization of CAP.  

We also request clarification on how MCOs are expected to use this information, including whether CAP notification is intended to trigger specific actions such as enhanced monitoring, network participation review, or other corrective measures, and whether there will be standardized criteria across MCOs to ensure consistent response.  

We recommend DMAS operationalize this requirement by defining: 

• The minimum content that must be included in the notification (scope, findings, corrective steps, and timelines)  

• Whether providers must provide updates or closure documentation when the CAP is resolved 

• How this requirement interacts with existing MCO oversight and quality monitoring process to avoid duplicative reporting 

Clear, consistent guidance on these points will help ensure that CAP reporting is implemented uniformly across the system, supports meaningful oversight, and does not create unnecessary administrative burden or variability in interpretation.