The following summarizes feedback regarding the "Required EBPs" section received from our members since the draft policy was released:

Training and Capacity Concerns

• MAP Training Access and Cost: Many LMHPs have been denied access to MAP training due to limited capacity at CEP-VA. Agencies need clarity on timelines, funding, and whether the state or agencies will bear training costs.
• Training Duplication and Burden: MAP may duplicate existing EBP credentials. Intensive, mandatory trainings (MAP and foundational modules) could strain smaller providers’ staffing, cost, and scheduling capacity.
• Implementation Timeline: Agencies need advance notice (by March 1, 2026) of training requirements to budget and plan before the July 1, 2026, rollout.
• Credentialing and Flexibility: Clarify timeframes, costs, and flexibility for MAP certification (which may exceed $700 per clinician). Consider “train-the-trainer” options or financial support.

Evidence-Based Practice (EBP) Processes

• CANS Lifetime Notification: Clarify who within each MCO should be notified when CANS results indicate a fit for a standalone EBP.
• Referral Burden: CPST providers shouldn’t be expected to assess for EBPs they’re not trained in; MCOs are better equipped to make those determinations.
• Billing and Documentation: Agencies need to know whether EBP assessments, coordination, or attempts to link clients to EBPs are billable and what proof of effort will be required.
• Duplication of Services: CPST psychotherapy requirements overlap with existing outpatient services.

Rate and Reimbursement Questions

• Measurement-Based Care: Unclear whether using optional assessment tools will increase reimbursement or simply use existing authorized units.
• Reimbursement for Coordination: Agencies ask if coordination efforts beyond standard time limits can be billed.

Service Delivery and Operational Limits

• Supervision Cap: The rule limiting each LMHP to nine supervisees is impractical, especially for small or rural agencies that depend on part-time or flexible staffing models.
• Overlapping Service Definitions: Need examples showing how the new CANS and Comprehensive Needs Assessment integrate, including estimated completion time and confidentiality safeguards.