The CPST draft requires “two or more members of a team consisting of professional and paraprofessional staff, offering a combination of medically necessary community-based interventions.” This LMHP-driven model is significantly more expensive than MHSS or IIH, which rely primarily on QMHP staff.

The 2023 Appropriation Act, Items 304.VVVV.1 and 304.VVVV.2, directed DMAS to increase behavioral health reimbursement rates by 10 percent, with additional increases under Item 304.WWWW. However, CPST is being introduced without a specific appropriation or tiered reimbursement structure. This risks violating 12VAC30-80-30, which requires DMAS to set rates sufficient to ensure provider participation, as well as the federal Medicaid access requirement at 42 U.S.C. §1396a(a)(30)(A).