To support successful statewide implementation, we respectfully request that DMAS increase flexibility in supervision, allow training equivalencies and portability, publish and pilot the CANS algorithm, adjust Tier Two intensity, revise crisis requirements to consultation-based models, define the licensing category, extend accreditation timelines, allow wraparound and transitional services, and streamline documentation requirements.
1. Supervision Requirements
The revised draft sets weekly face-to-face supervision, minimum monthly supervision hours, and a supervision load per LMHP that together exceed feasible operational capacity and significantly reduce billable time. Permit flexible supervision models, including group supervision, tele-supervision, team-based case review, and case-based supervision equivalencies aligned with DBHDS standards. A higher LMHP oversight capacity should be permitted when licensed staff conduct structured team reviews.
2. Training, MAP Credentialing, and CEP-VA Requirements
Mandatory MAP credentialing, Foundational Skills curricula, and additional CBT requirements create redundant and excessive training burdens that overlap with existing DBHDS-required training. Recommend accepting equivalent prior training (e.g., CBT, TF-CBT, MI, trauma-informed care), implementing a phased credentialing timeline of 24–36 months, clarifying MAP supervisory roles, and allowing portable online modules compatible with existing learning management systems.
3. CANS Lifetime Tool and Authorization Pathways
The CANS Lifetime Level-of-Need algorithm remains undefined, yet it directly determines admission, tier assignment, service intensity, and staffing. This creates uncertainty for providers and payers. Recommend releasing the scoring algorithm for public review, pilot-testing LON thresholds with a representative group of providers, and publishing a clear crosswalk between CANS domains and functional criteria.
4. Tier Two Service Frequency
Tier Two CPST requires 5–8 hours per week, approaching IICRT/ICT-level intensity without the corresponding staffing model or reimbursement. This intensity is not operationally feasible for all individuals. Recommend reducing Tier Two expectations to 3–6 hours per week unless higher medical necessity is documented, and clarifying that the range is an average rather than a mandatory minimum.
5. Crisis Response Requirements
Requiring CPST providers to deliver in-person crisis response 24/7 before referral to 988, CSB Emergency Services, or Mobile Crisis effectively mirrors crisis stabilization services. This expectation creates duplication and unfunded liability. Recommend limiting CPST responsibilities to 24/7 on-call consultation and safety planning, ensuring immediate access to external crisis services when safety concerns arise, and aligning requirements with the existing Mobile Crisis model.
6. Undefined Licensing Category
The CPST licensure category remains “To Be Determined,” which prevents providers from planning for compliance, staffing, and licensure timelines. Recommend publishing the draft CPST licensure category alongside the service definition and clarifying whether CPST aligns with Outpatient Services, Psychoeducational Rehabilitation, or a new licensure category.
7. Accreditation Timeline
Requiring CARF, COA, or TJC accreditation within 18 months of July 1, 2026, is not feasible for most providers. Recommend extending the accreditation timeline to 36–48 months to support realistic implementation.
8. Exclusion of Individuals Eligible for Other EBPs
The revised draft excludes individuals eligible for services such as Assertive Community Treatment, Coordinated Specialty Care, Multisystemic Therapy, Functional Family Therapy, or Applied Behavior Analysis unless those services “fail.” This restriction risks care fragmentation and service gaps. Recommend allowing CPST as a wraparound or step-down service when clinically justified and permitting concurrent CPST during transition periods of up to 90 days.
9. Documentation Requirements
The documentation requirements are highly prescriptive and may exceed federal Medicaid standards, increasing the administrative burden without corresponding clinical benefit. Recommend simplifying progress notes to core elements (intervention, response, progress toward ISP goals, and next steps) and permitting co-signatures or scribing when clinically appropriate.