MST Provider Qualifications:

• 33% of the team can be very confusing, we suggest modifying this language to “One member of the team can be a QMHP- E/QMHP-C/CSAC/CSAC-supervisee.    As MST consist of teams of 2-4 professionals, 1 team member would support staff turn-over and best practices in hiring and reduce confusion. 
• Since MST/FFT Professionals are not “therapists” per the definitions on page 3, this should be in alignment with MST/FFT requirements or at the very least restrict QMHP-Es to 33% of the team. Otherwise, there’s no distinction between a QMHP and an E. Taking into account the overall labor shortage in the country and the shortage of professionals in the field in the country and the state, this is going to be restrictive and limit service availability for both MST and FFT

Staff requirements: 

• Currently states: The MST team composition includes a full-time LMHP, LMHP-R, LMHP- RP, or LMHP-S who acts as the MST Supervisor, and a minimum of two to a maximum of four MST Professionals who provide available 24-hour coverage, 7 days a week.
• What if they have a unique situation where they have 1 supervisor and 1 staff but it’s approved by MST?  Or is the team is undergoing staffing changes and they dip below 2 Professionals?

Admission Criteria:  Could the admission criteria include

#2Why are services limited to such a specific diagnosis (primary diagnosis categories of disruptive behavior, mood, or substance use disorders)?  This raises concerns that a lot of youth may receive an incorrect diagnosis which they will be labeled with for life. Is there data or research from MST  that limits this scope?  If the youth has another diagnoisis, with other needed comments, could it 

# 3 – Consider adding e) The youth is adjudicated and placed on probation or parole, similar to the language in the FFT guidance.  

#6 – family or caregiver – Is there a way to clarify the youth must  have an available semi-permanent or permanent caregiver and the youth RESIDES with family or caregiver (or list this as an exclusionary criteria?)

Suggest removing #7 as it appears to duplicate other areas and provides no substantive criteria.

#8 Currently states:   If there is an order through juvenile justice for participation in community-based treatment, the youth meets the other medical necessity criteria.  Suggest removing #8 entirely – as it says youth must meet ALL of the criteria – this not all youth will have DJJ involvement.  The word ORDER – suggests a court order which is not appropriate and will cause confusion.  If you want to include DJJ request, could it be an option (for example, youth must meet a certain number or