Despite the overwhelming deterrence of CPST’s complexity and cost, for those who will commit to providing these services, the overwhelming diffusion of responsibility opens the door to opportunities for fraud, waste, and abuse. Providers now must report information to a myriad of entities, only a few of which are responsible to ensure that licensed providers are living up to their overall commitments. Such diffusion of responsibility has never been known to increase compliance. In fact, quite the opposite. If no one is wholly responsible, few can see the big picture of any one provider’s performance. Bystander effect further lowers the probability of "bad" providers being reported to DBHDS or DMAS and held accountable. And as for those truly responsible for holding providers accountable, how will they see and measure compliance that is spread far and wide?
For each added reporting rule, there ought to be a planned system of measurement and accountability. If impossible, ditch the reporting rule or make them a recommendation and not a rule. Good providers do not want bad providers any more than DMAS does as they render us all vulnerable to this kind of bureaucratic overreach and leave our clients with fewer and fewer services.
In these Draft Regulations, providers now report to (likely missing some):