3.2.2    This comment has been made on earlier versions:

• By creating the foundational service (CPST) as an option only if other services are “inappropriate” or “unavailable”
• The expectation that a provider who meets the requirements for providing CPST also meets the requirements to conduct the needed assessment for ACT, CSC, FFT or MST (several of which are proprietary and require nationally recognized specialized training) or that the time/effort required (and uncompensated) will be beneficial for the individual is unrealistic.
• Identification of the most appropriate service accessible and available is the responsibility of the referring agent or, in the case of self referral the provider’s assessment of their ability to meet the needs.

4.2        Related to this and similar requirements for staffing

• While it is clear that part of the intent is to assure qualified staffing and supervision, and it is an intent that we can support, it is also clear that there is a significant bias against smaller provider entities which do not have “deep benches” of licensed professionals. 
• The termination of the option for a variance on a date certain (6/30/2029) suggests that past that date, staffing (recruitment & retention) will no longer be an issue.  We see no reason to assume that clinical staffing will be more readily available in three years!

5.3.2    Crisis Support

• References in B & D to MCOs are intentionally misleading; MCOs are bound by their contract not by a DMAS Manual and:
  • All operate differently
  • None operate consistently
  • “Contact the MCO” has no functional meaning so can neither be monitored nor relevant
  • Section D implies “real-time” involvement which is not a functional concept in the current environment

5.5        Care Coordination – see comment to 3.3.2 above