I think the biggest area that could benefit from additional clarification is how medical necessity fits into the overall CPST framework. There is a lot of emphasis on the CANS Lifetime assessment and Level of Need, but it isn't entirely clear how those relate to the determination that CPST is medically necessary.

Is the CANS intended to determine eligibility for CPST, or is medical necessity established first, with the CANS then helping determine the appropriate Level of Need and service intensity?

I think this section could benefit from clearer admission criteria and a more straightforward explanation of how these pieces fit together. The current IIH, MHSS, and TDT regulations provide a clearer framework for determining when those services are appropriate. With the proposed CPST framework, it's more difficult to follow how providers are expected to move from the assessment to determining that CPST is the medically necessary service.

That matters because providers need to be able to confidently identify who this service is intended for and who may be better served by another behavioral health service. Individuals seeking behavioral health care already face enough barriers to accessing services. Clear, understandable criteria will help providers connect Medicaid members with the right level of care sooner, whether that's CPST or another service.