I appreciate DMAS’s continued efforts under Right Help, Right Now to expand access to behavioral health care for youth and families within educational settings. Integrating community psychiatric supports into schools can strengthen prevention, early intervention, and care coordination. However, the proposed CPST – School Setting model raises several implementation and compliance concerns that must be addressed before adoption.

1. Service Duplication and Licensing Clarity

The CPST–School Setting draft overlaps with existing Medicaid and DBHDS-licensed services, including Intensive In-Home (H2012), Therapeutic Day Treatment (TDT), and School-Based Mental Health Supports funded under the Virginia Department of Education’s Tiered Systems of Support (VTSS).
Under 12VAC30-50-226 and Appendix H of the Mental Health Services Manual, these programs already authorize in-school interventions targeting the same youth population and functional outcomes.
DMAS should clearly define how CPST-School differs from TDT or IIH to avoid duplication and potential CMS disallowance under 42 CFR §440.130(c).

2. Workforce Readiness and Training Burden

The draft requires extensive credentialing: LMHP-led teams, MAP certification, trauma-informed and crisis skills, and CANS Lifetime training through CEP-VA.
While clinically appropriate, these expectations will impose significant cost and time burdens on community providers already facing workforce shortages.
DMAS should phase in these training requirements with financial support, CEU reimbursements, or grants, and allow cross-credit for staff who already completed equivalent MHSS, IIH, or Crisis service trainings under Appendix G & H.

Agencies must also receive clear guidance on which training platforms are approved—such as VCU CEP-VA, DBHDS Workforce Development, and TCOM/Praed Foundation for CANS—to ensure compliance and audit readiness.

3. PRS and CSAC Role Inclusion

The draft limits CPST-School staffing to LMHPs, QMHPs, and Behavioral Health Technicians. This exclusion of Peer Recovery Specialists (PRS) and Certified Substance Abuse Counselors (CSAC) conflicts with the state’s current investment in peer integration and substance-use navigation within youth programs.
Under 12VAC35-105-20 and 42 CFR §438.12 (Any Willing Provider), qualified PRS and CSAC professionals should be recognized contributors to the CPST-School team under LMHP supervision. Their presence is particularly important for school-based prevention and recovery initiatives.

4. Reimbursement and Rate Structure

The CPST–School model includes LMHP supervision, MAP fidelity monitoring, and coordination with educational staff—all of which increase administrative costs.
Current behavioral-health rates, even after the 10 percent increase mandated by Appropriation Act Item 304.VVVV, will not sustain this structure.
DMAS should publish the proposed rate methodology under 12VAC30-80-30 and confirm that it accounts for supervision, travel between schools, and non-billable collaboration time with teachers and counselors.

Without a sustainable rate, small and mid-size agencies—especially minority-owned providers—will be unable to participate, reducing network adequacy and violating 42 U.S.C. §1396a(a)(30)(A) access standards.

5. School Collaboration and Parental Consent

Section 4.5 of the draft requires collaboration with schools and families, yet lacks detail on FERPA and HIPAA coordination.
DMAS should issue joint guidance with VDOE and DBHDS to clarify consent procedures, data-sharing agreements, and privacy safeguards so that providers can remain compliant with both HIPAA and FERPA while coordinating care within school settings.

6. Accreditation and Implementation Timeline

The requirement for agencies to obtain CARF, COA, DNV, or Joint Commission accreditation within 18 months of July 2026 is commendable but unrealistic for new or small agencies.
DMAS should consider a tiered compliance timeline—for example, allowing provisional participation for 24 months with documented progress toward accreditation—consistent with 12VAC35-105-50(B) flexibility standards.

7. Recommendations

Clarify the CPST-School service definition to distinguish it from IIH and TDT.

Explicitly include PRS and CSAC under LMHP supervision.

Publish rate methodology ensuring cost neutrality and sustainability.

Approve statewide training vendors and offer tuition assistance or CEU reimbursement.

Issue joint DMAS-DBHDS-VDOE guidance on confidentiality, parental consent, and data-sharing.

Implement a phased accreditation timeline to protect smaller providers and maintain access.

Conclusion

The concept of CPST within school settings has strong potential to close service gaps and support youth mental-health recovery.
However, successful implementation requires clear service differentiation, equitable workforce inclusion, sustainable reimbursement, and coordinated regulatory guidance.
DMAS should revise the CPST-School draft accordingly to ensure compliance with 12VAC35-105, 12VAC30-50-226, 12VAC30-80-30, and federal standards at 42 CFR §440.130(c) and 42 U.S.C. §1396a(a)(30)(A).