Just N Time submits these comments in its consulting capacity, advising behavioral health agencies preparing for CPST and CSC. These comments request practical implementation guidance and do not represent statements about any individual client agency's compliance.

1. Billing responsibility. Please specify who may bill for an assessment when a certified QMHP completes ratings and a separately qualified clinician completes the diagnostic evaluation and formulation. Clarify rendering and billing provider requirements, whether components may be completed by different agencies, duplicate-billing controls, permitted codes and units, same-day restrictions, and what work is included in the service payment. Please provide examples distinguishing separately billable comprehensive reassessments from periodic updates included at the service level.

2. Reassessment timing. Please publish a single schedule distinguishing initial assessments, routine updates, annual reassessments, and event-triggered reassessments. Define the events that trigger a new assessment, the completion deadline, how timing relates to authorization expiration and ISP review, and which requirements apply to members transitioning from legacy services. Explain how care and payment will be handled while an updated assessment or authorization is pending. Include examples for both adult and youth CPST and CSC.

3. Assessor and supervisor certification. Please clarify whether CANS certification is required of every clinical supervisor, only individuals co-signing CANS, and/or the diagnosing clinician who signs the clinical formulation without independently assigning ratings. Identify approved training, the definitive passing standard, renewal requirements, evidence accepted for verification, and the consequences of certification lapses. Publish training availability and expected costs early enough for agencies to prepare.

4. Diagnostic signatures. Please identify which practitioner credentials may complete and sign each assessment component, including supervised practitioners. Clarify whether an existing diagnostic evaluation may be incorporated, acceptable timing between ratings and diagnostic signatures, and how corrections or disagreements between clinicians should be documented.

5. EHR feasibility and conditional modules. Please publish the final data dictionary, age-specific requirements, trigger logic, mandatory-versus-optional module list, and version-control expectations. Clarify whether an integrated EHR assessment that preserves all required content is acceptable instead of reproducing the state's template exactly. Specify acceptable electronic signatures, amended-record audit trails, export formats, and any required submission platform or interface. Allow sufficient vendor implementation time after final specifications are released.

6. Authorization attachments. Please issue a uniform checklist identifying precisely what must accompany initial and continued-service requests for managed care and fee-for-service. Explain whether the entire combined assessment, a structured extract, or other documentation is required, how the agency will verify receipt, and how omissions may be corrected without unnecessary interruption of care.

7. Audit retention and implementation. Please state the applicable retention periods and starting events for assessment versions, certification evidence, diagnostic signatures, authorization submissions, and electronic audit trails, including any different requirements for minors or records under audit or legal hold. Please publish the final policy, effective dates, training schedule, and transition instructions together, and identify which provisions remain draft until finalized.

Clear, consistent guidance across DMAS and managed care plans will help agencies budget for training and EHR changes, assign clinical responsibilities, and reduce avoidable authorization delays and claim denials.

Tiffany Robinson
Just N Time