We appreciate the significant effort that has gone into redesigning the Community Psychiatric Support and Treatment (CPST) service model and support the goal of improving quality and consistency of care. However, the proposed model is not financially or operationally feasible under the reimbursement rate currently proposed.

The proposed rate is based on the lowest end of the range identified in the Mercer rate study, while the draft manual substantially expands provider responsibilities through increased documentation, staffing, supervision, training, reporting, assessment, care coordination, and administrative requirements. These new expectations represent a significant increase in the cost of delivering CPST that is not reflected in the proposed reimbursement.

As written, providers will be required to absorb substantial unfunded administrative costs. This will divert resources away from direct clinical care, reduce provider capacity, worsen workforce recruitment and retention challenges, and may ultimately reduce access to services for individuals who rely on CPST.

If the reimbursement rate cannot support the full model, the administrative requirements should be scaled to match the available funding. A phased implementation would allow providers to focus resources on delivering high-quality clinical services while preserving access to care until a sustainable reimbursement rate is established.

The following requirements should be removed, delayed, or substantially streamlined until reimbursement adequately supports the proposed model.

Eliminate duplicative assessment requirements

The CANS Lifetime should either replace existing assessment requirements or remain optional until conflicts with current licensing requirements are resolved. Providers should not be required to complete multiple comprehensive assessments covering the same information.

Reduce documentation requirements

Documentation expectations should be limited to information necessary to support medical necessity, treatment planning, and quality care.

The following requirements should be removed or deferred:

• Documentation of each individual evidence-based practice protocol within the Individual Service Plan.
• Quarterly updates documenting each evidence-based practice protocol.
• Documentation explaining why every standalone evidence-based practice was or was not used.
• Additional documentation associated with mandatory referrals to standalone evidence-based practices.
• Expanded crisis plan documentation beyond current clinical standards.
• Separate documentation requirements that duplicate information already contained in assessments, treatment plans, or progress notes.

Reduce Managed Care Organization reporting requirements

Several proposed reporting requirements create significant administrative work without improving clinical care.

The following should be eliminated:

• Notification to the Managed Care Organization every time an individual accesses crisis services.
• Reporting DBHDS corrective action plans to Managed Care Organizations.
• Repeated documentation of communication with Managed Care Organizations when information is already available through existing utilization management processes.

Preserve existing care coordination responsibilities

Care coordination already performed by Mental Health Case Managers should not be duplicated by CPST staff. Existing qualified case management services should continue to satisfy care coordination expectations whenever those services are already in place.

Streamline supervision requirements

Current supervision expectations require substantial increases in licensed staff time that are not reflected in reimbursement.

The following should be reconsidered:

• Mandatory LMHP review every 30 days for every individual regardless of clinical need.
• Routine co-signature requirements for staff documentation when supervision has already occurred.
• Increased supervision frequency requirements beyond current licensing standards.
• Requirements that the Clinical Director provide in-person intervention without allowing delegation to another qualified licensed clinician.

Reduce workforce-related administrative costs

Implementation should avoid creating unnecessary barriers to workforce recruitment.

Until reimbursement supports these expectations, providers should not be required to:

• Obtain multiple new certifications beyond existing professional credentials.
• Maintain duplicate training records in multiple reporting systems.
• Complete additional reporting through CEP-VA when documentation is already maintained by providers and available during audits.

Eliminate unnecessary caseload tracking requirements

Providers should not be required to maintain formal monthly caseload calculations and six-month averaging logs solely for compliance purposes. Existing quality assurance and staffing processes are sufficient to monitor workloads.

Limit referral documentation

When specialized evidence-based practices are unavailable, providers should only be required to document that appropriate alternatives were considered. Extensive documentation regarding referral efforts, provider availability, and Managed Care Organization coordination creates significant administrative burden without improving access when services do not exist in many communities.

Recommendations

Until reimbursement reflects the actual cost of the proposed service model, implementation should focus on maintaining access to direct clinical services by:

• Prioritizing direct service delivery over administrative requirements.
• Eliminating duplicative documentation and reporting.
• Aligning assessment requirements with existing licensing standards.
• Allowing providers flexibility in supervision and staffing.
• Reducing duplicate reporting to Managed Care Organizations, CEP-VA, and other entities.
• Preserving existing care coordination responsibilities rather than creating overlapping duties.
• Delaying implementation of enhanced administrative requirements until reimbursement supports the associated costs.

The proposed clinical model may ultimately improve quality, but it cannot be implemented successfully if reimbursement does not support the infrastructure required to operate it. Without meaningful reductions in administrative requirements or a sustainable reimbursement rate, providers will face increased operating losses, reduced staffing capacity, and diminished access to medically necessary behavioral health services.

We respectfully request that DMAS align regulatory expectations with available funding by either establishing a reimbursement rate that reflects the true cost of the proposed model or reducing administrative requirements until sustainable funding is available.