I have some concerns about the requirements for CBPS supports.  First and foremost is the fact that my MH Residential program currently does not have an LMHP on staff, as we do not provide psychotherapy and our clients receive this service from other providers.  Would that provider be able to write their residential treatment plans?  If the QMHP that works with them daily attended, I suppose that would solve the problem of them not being familiar with in home supports or the client's day to day activities.  It would seem more cost effective, however, to have the actual person working daily with the client to do the plan.  I am also concerned that their therapist would not be willing to do this, as completing their treatment plans and other paperwork, apparently, is not a billable service.  Why isn't completion of paperwork reimbursable?  If it is required, it should be reimbursed.  

Regarding the requirement for the staff the service the individual daily to also be available to provide 24 hour Crisis Support--is it fair to the person who normally works with 10 clients twice weekly for two hours to suddenly be available for an overnight weekend shift to support an individual in crisis?  Given that they have 10 clients--it could end up happening a lot.  What if they have already worked 40 hours that week?  What if they are not trained in the supports needed to manage individuals in crisis--such as the use of restraints--and these supports are not available in the community setting? I'm not sure having staff remain with a client who is escalating and needs a higher level of care is even a good idea, from a safety standpoint.  I would like to see more detail regarding what this support would look like--and how much more reimbursement would be received by the provider, as the provider would be working overtime, and additional staff might be needed to prevent neglect to other clients.

I am also concerned about the assumption that clients will agree to increased support and intervention.  It has been my experience that clients often refuse treatment as they become more symptomatic.  If the client refuses interventions to help them stabilize--such as a medication change--what happens?   

Finally, I am wondering what happens to individuals who are not making progress, but are currently being served in the least restrictive environment that can meet their needs.  Are they to be forced back into a higher level of care that they do not actually need?  Transitioned before they are ready to a lower level of care, which sets them up for failure and will likely result in either hospitalization or homelessness?  I am not sure how either of  these two options is advantageous over the option of letting them remain where they are, if they are stable and happy with their supports.