The current billing structure indicated is likely to create operational challenges. While the draft permits simultaneous billing for assessment and treatment planning, these services share the same CPT codes as other CPST components. Without clear differentiation at the claim level, systems may incorrectly flag valid concurrent billing as duplicate or overlapping services.

Greater specificity in billing codes and/or modifiers is needed to clearly distinguish CPST service components. Without this clarity, both MCO and Medicaid claims systems may face implementation challenges, potentially disrupting claim adjudication and creating unnecessary administrative burden.

Ensuring sufficient billing detail is critical to support a seamless implementation and to avoid unintended negative impacts on provider reimbursement.