Behavioral Health Redesign

Since the “official Medicaid Bulletin” on August 20th, we have been attempting to develop and ask the “right” questions to have clarity and understand the actual planned implementation of the
Behavioral Health Redesign. 

We will  collect the information here to give you a point of reference as you contemplate how and/or if you will move forward with the new services.    

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Link for informal public comment on a redraft of the “manual” for Youth & School-based CPST (closing on September 20) available here 

This is the link to the website page describing Redesign

Answers  to questions below from Lisa Jobe-Shields!


DBHDS Licensing Regulations (Emergency/Final)

12VAC35-105-1421 Admission criteria

A. Before a CPST provider may admit an individual to Tier 1 CPST, the individual shall meet the criteria for admission as defined by this chapter and the provider’s policies. The provider’s policy regarding admission to Tier 1 CPST shall, at a minimum, meet the requirements of 12VAC35-105-650 and the assessment required by that section shall document that the individual:

1. Has a primary ICD diagnosis or DSM diagnosis for mental illness; or

2. An unspecified or provisional diagnosis indicating behavioral health needs; and

3. For children and adolescents, an identified caregiver who lives in the same household shall be willing to participate in the service, as clinically appropriate.

B. Before a CPST provider may admit an individual to Tier 2 CPST, the individual shall meet the criteria for admission as defined by this chapter and the provider’s policies. The provider’s policy regarding admission to Tier 2 CPST shall, at a minimum, meet the requirements of 12VAC35-105-650 and the assessment required by that section shall document that the individual:

1. Has a primary ICD diagnosis or DSM diagnosis for mental illness;

2. Meets the criteria for early serious mental illness, serious mental illness, or serious emotional disturbance; and
3. For children and adolescents, an identified caregiver who lives in the same household shall be willing to participate in the service, as clinically appropriate.

12VAC35-105-1422 Discharge criteria

Before a CPST provider may discharge an individual, the individual shall meet the criteria for discharge as defined by this chapter and the provider’s policies. The provider’s policy regarding discharge shall, at a minimum, meet the requirements of 12VAC35-105-693 and also require the individual to:

1. No longer meet admission criteria; or

2. Successfully meet the specific goals outlined in the treatment plan for discharge; or

3. Have not made progress on established service goals, nor is there expectation of any progress with continued service; or

4. No longer be engaged in the service, despite multiple attempts on the part of the provider to apply engagement strategies as defined within their policies; or

5. No longer need the service, as the individual is obtaining similar benefit through other services and resources.

12VAC35-105-1423 Treatment team and staffing

A. CPST providers shall have sufficient staffing composition to meet the varied needs of individuals served by the provider as required by this section. Each CPST provider shall meet the following minimum position requirements:

1. A full-time clinical director who is a LMHP.

2. A LMHP with at least one year of experience working with individuals experiencing SMI or SED shall be available for consultation 24 hours a day, seven days a week.

B. Each CPST team shall meet the following minimum staffing requirements:

1. A LMHP who shall supervise the team, oversee the assessment and the ISP, and authorize the ISP. Assessments and ISPs may be completed by an LMHP, LMHP-R, LMHP-RP or LMHP-S; and

2. Every LMHP, LMHP-R, LMHP-RP, LMHP-S, QMHP, and QMHP-T shall be trained in evidence-based practices and decision models for assessment, treatment planning, and implementation of behavioral health interventions.

C. All CPST staff shall provide services under the direct supervision of an LMHP.

D. Applicants for an initial conditional CPST license may submit a transition plan to the department for approval that will allow for “start-up” when newly forming providers are not in full compliance with the CPST model relative to staffing patterns and individuals receiving services capacity. A transition plan must be approved prior to the issuance of the license. Approved transition plans shall be limited to a six-month period.

12VAC35-105-1424 Service delivery and location

A. CPST programming shall take place in:

1. An individual’s home;

2. An individual’s community or natural settings; or

3. A provider’s department-licensed office location. Services provided in the provider’s department-licensed office location shall not exceed 50 percent of service delivery hours a week per individual served and shall be for the benefit of the individual.

B. CPST Tier 1 and Tier 2 programs shall meet the following programmatic requirements. The program shall provide:

1. Crisis support 24 hours a day, seven days per week. Crisis support shall include the development and implementation of a crisis mitigation plan, any additional crisis planning necessary for the individual, crisis avoidance, and crisis intervention. Crisis support shall be provided by a LMHP, LMHP-R, LMHP-RP, LMHP-S, QMHP, or QMHP-T. Before referring to any external crisis resource, the provider shall attempt internal crisis support.

a. Crisis support may occur via telephone or telemedicine. The individual’s needs and preferences shall be the determining factor regarding whether crisis support is provided in person, via telemedicine, or via telephone.

b. If the individual’s condition progresses and requires a higher level of care the individual shall be referred to the appropriate level of care.

2. Restorative evidence-based therapeutic interventions by a LMHP, LMHP-R, LMHP-RP, LMHP-S, QMHP or QMHP-T. If restorative evidence-based therapeutic Interventions is provided in a group with multiple individuals the ratio of team members to individuals served shall not exceed 1:8 for children and adolescents and 1:12 for adults.

3. Psychotherapy or counseling by a LMHP, LMHP-S, LMHP-R, or LMHP-RP acting within his scope of practice. If psychotherapy or counseling is provided in a group with multiple individuals the ratio of team members to individuals served shall not exceed 1:8 for children and adolescents and 1:12 for adults.

4. Care coordination on an individual basis by an LMHP, LMHP-R, LMHP-RP, LMHP-S, QMHP or QMHP-T.

C. CPST Tier 2 programs shall provide all the programmatic elements within B 1-4 and rehabilitation skills practice by a LMHP, LMHP-R, LMHP-RP, LMHP-S, QMHP, QMHP-T, or BHT. Rehabilitation skills practice shall be provided on an individual basis.

12VAC35-105-1425 Location requirements

A. All CPST providers shall have an office location. The office location shall be within the Commonwealth of Virginia and have regular business hours. The office location shall be staffed during regular business hours.

B. The CPST office location shall be appropriate for storage of records and group programming. Records storage space shall meet the requirements of 12VAC35-105-870. Programming space shall ensure the privacy of individuals served.

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Questions sent to Lisa-Jobe Shields, DMAS – August 25, 2026