Frequently Asked Questions

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Can Other Licensed Practitioner (OLP) be provided under a limited permit license?


Source: CFTSS June 2018

From a Workflow perspective, how do you get into CFTSS without going through an Other Licensed Practitioner (OLP)?

There are multiple examples of pathways into services including: 

  • If the child is in clinic receiving therapy, the clinician can make a recommendation for any of the new Children and Family Treatment and Support Services based on their determination of medical necessity.                
  • A pediatrician can directly recommend FPSS as they can support medical necessity.  
  • A school guidance counselor supporting a young man/woman who has come back from a residential setting with a parent who is concerned about positive peer group. The school counselor could refer any agency who providers PSR. The agency can access their own internal licensed practitioner for assessment and determination of medical necessity or work with the parent to identify a treating clinician for documentation of medical necessity to allow the service.
  • In foster care there is a requirement that youth have a full array of health and behavioral assessments by licensed practitioners, which could result in a recommendation for one or more of these services.

Source: CFTSS June 2018

For CFTSS, what is the difference between LPHA and NP-LBHP?

NP LBHP is specific to those practitioner categories that can provide services under OLP. They can make recommendations for any of these services. LPHA is a broader definition and includes additional treating practitioners (i.e. primary care doctor) who can make a recommendation for one of these services. 

Please refer to the CFTSS manual for a list of these practitioner types at:

Source: UM for CFTSS: OLP, PSR, CPST 9.18.18

In CFTSS if the youth is enrolled in Health Home Care Management, does the Plan of Care replace the treatment plan?

No. The Health Home Care Manager determines what services are needed, facilitates referrals, and develops a HH Plan of Care. The treatment plan is developed by the treating practitioner who provides the direct services. The Agency/practitioner providing direct services is responsible for maintaining the treatment plan. 

For more information on the differences between treatment/service plans and Plan of Care, see state guidance.

Source: UM for CFTSS: OLP, PSR, CPST 9.18.18

What is the difference between OLP services and therapeutic services through the Article 31 clinic? How do we distinguish when each is appropriate/when to bill for which?

The new OLP services are intended for children who have not or are not well suited for clinic based treatment, and would be better served in their home or community.  OLP services only include assessment, treatment planning, psychotherapy and some crisis interventions. OLP can only be billed for children admitted to the service.

Clinics can offer a full array of clinical treatment interventions, including but not limited to medication management and psychiatric evaluation.  Clinic services are to be billed for any child enrolled in clinic. 

Source: CFTSS: OLP, PSR, CPST Billing and UM Office Hour 11.15.18

What is within the scope of an LPHA’s practice as related to recommending CFTSS?

Page 91 of the CFTSS Provider Manual outlines which LPHA can make a recommendation for CFTSS:

An individual professional who is licensed as a Registered Professional Nurse, Nurse Practitioner, Psychiatrist, Licensed Psychologist, Licensed Psychoanalyst, Licensed Master Social Worker (LMSW), Licensed Clinical Social Worker (LCSW), Licensed Marriage & Family Therapist, Licensed Mental Health Counselor, Licensed Creative Arts Therapist, or Physician (per OMH 599 regulations) and practicing within the scope of their State license to recommend Rehabilitation services.

Please note: While all listed LPHA can make a recommendation, not all have the ability to diagnose a child independently, if needed, within their scope of practice without being under the supervision of another qualified licensed practitioner or physician.

Source: State January Roundtable 2019

Can a child's family or teachers directly refer to an OLP?

A family, teacher, or other non-clinician may refer directly to an OLP without first going to another LPHA.

When a non-clinician refers directly to OLP, the OLP provider will determine whether the child meets the medical necessity criteria to continue receiving OLP and/or recommend for other CFTSS.

Source: State January Roundtable 2019

If a family does not have a child with a substance abuse issue would a Certified Recovery Peer Advocate Family (CRPA-F) be able to work with the parent to provide Family Peer Support Services (FPSS)?

FPSS work to improve the situation of the family in relation to the needs of the child. Family peers have lived experience as a parent of a child with mental health needs or substance use needs and the corresponding certification or credentialing. Therefore, the use of a family peer should take into consideration the needs and diagnosis of the child.  

Typically, the CRPA-F would assist the parent or caregiver to address the needs of their child with a substance abuse issue.  Whereas, the credentialed FPA would work with a parent or caregiver of a child with a mental health need. 

Source: FPSS Preparing for MC Webinar May 2019

Does the Family Peer Advocate (FPA)/Certified Recovery Peer Advocate Family (CRPA-F) write the treatment plan?

Yes, they create the treatment plan based on the needs of the child and family. The FPSS would engage in a conversation with the child and family and use the information provided by the LPHA to determine what intervention/activities would take place within the scope of the service to support the goals and objectives developed. 

Although there is no specific assessment for this, OMH does endorse the use of the Family Assessment of Needs and Strengths (FANS) which will assist FPSS providers in honing-in the on a family’s strengths and needs.  This conversation would result in the development and implementation of a treatment plan. 

More information on the FANS can be found at:

Source: FPSS Preparing for MC Webinar May 2019

The documentation does not say that the LPHA who makes the Family Peer Support Services (FPSS) recommendation "MUST" be involved in the creation/coordination/oversight of the treatment plan and most clinicians (pediatricians/school SW/LPHAs) are not going to want to have more responsibility than is required. What is the protocol in these situations? Can FPSS providers create their own treatment plans with caregivers and submit them to the Medicaid Managed Care Plan (MMCP) without the oversight of any other authority?

The FPSS provider can develop their own treatment plan, with the oversight and approval of the FPA supervisor.  The plan, however, should be guided by the needs and functional limitation of the child identified by the recommending LPHA.
Ongoing involvement of the LPHA recommending the CFTS service is not required. However, as with all mental health service provision, coordination of care between service providers or through a multi-disciplinary approach, is most effective.
If the recommending LPHA is also part of the FPSS provider agency, they may play a more active role in the treatment plan and serve as a member of the multi-disciplinary team on an integrated treatment plan.  
If the LPHA is not within the same agency, wherever possible, FPSS providers are encouraged to coordinate with external agencies to ensure their work supports the efforts of other treatment providers and helps to inform their own activities. 

Source: FPSS Preparing for MC Webinar May 2019

Can a child be recommended for HCBS and CFTSS?

Yes, a child may meet criteria for both based on medical necessity for CFTSS and meeting HCBS threshold criteria.  The Health Home Plan of Care should identify what goals each service is intended to address.  Each service would have its own service or treatment plan.  

Source: Children's HCBS Webinar Series March 2019

Who writes the Crisis and Safety Plan for the child as part of CFTSS Crisis Intervention?

The Crisis/Safety plan is written by the service provider who is delivering the service. This provider must be a designated entity and meet the necessary qualification as identified in the CFTSS Provider Manual.

Source: Children's HCBS Webinar Series March 2019

What is the maximum number of individuals that can participate in a CFTSS Family Peer Support Services (FPSS) group session?

The maximum number of individuals that can participate in a group session is 12, regardless of insurance type.

Source: FPSS Billing Nov 2019

Does the maximum number of individuals participating in a CFTSS Family Peer Support Services (FPSS) group session include children participating with parents in a FPSS parenting group?

Yes, it includes all active participants, including children and parents.

Source: FPSS Billing Nov 2019

Does the maximum number of individuals participating in a CFTSS Family Peer Support Services (FPSS) group session include children not actively participating, who happen to be there with their parents?

No, if other children are present due to, for example, lack of babysitting and not actively involved they do not count towards the group number. 

Source: FPSS Billing Nov 2019

Is a group note required as well as an individual note for each child/youth you bill for in an Family Peer Support Services (FPSS) group session?

There should only be 1 note per client/child per session. 

Source: FPSS Billing Nov 2019

Is Family Peer Support Services (FPSS) technically a collateral service because it works with the parent rather than the child?

The family/caregiver is not a collateral in this instance; others like the school, community members, etc. would be collaterals. Sessions with only collaterals are not allowed for FPSS. Instead, the State encourages FPSS staff to include the family/caregiver in conversations with the school or other collaterals to promote empowerment and skill development.

Family should always be present for the provider to bill for FPSS.

Source: FPSS Billing Nov 2019