The Ohio CPST changes under discussion in 2026 are a proposal, not a final rule. On July 16, 2026, the Ohio Department of Medicaid (ODM) proposed eliminating community psychiatric supportive treatment (CPST) from Ohio Administrative Code (OAC) rule 5160-27-02 and splitting that work between therapeutic behavioral services (TBS) and psychosocial rehabilitation (PSR). As of September 2026, no filed or final version of the rule could be confirmed.
ODM presented the idea at a provider stakeholder office hours session titled "Community BH Services proposed Rule Change Review." The presentation slides cover five rules in OAC Chapter 5160-27. ODM asked each billing provider organization to send one collective response by end of business Wednesday, July 22, 2026.
This guide is for owners, clinical directors, and billers at Ohio community behavioral health agencies. It explains what ODM proposed and why, what is final today, and how to prepare without guessing at dates.
What ODM proposed for CPST, TBS, and PSR
For rule 5160-27-02, ODM's stated objective is to "reduce duplication of services." The proposed strategy is one line: "Eliminate CPST from rule." ODM asked providers two questions. What decides whether a rendering provider bills CPST instead of TBS? And what would removing CPST do to service delivery?
CPST is defined today in OhioMHAS certification rule OAC 5122-29-17, effective September 16, 2018 (OhioMHAS is the Ohio Department of Mental Health and Addiction Services). That rule describes CPST as "an array of services delivered by community based, mobile individuals or multidisciplinary teams." It is billed as H0036.
The proposal for OAC 5160-27-08 gives TBS and PSR separate purposes:
- TBS individual: psychoeducation and supportive interventions informed by evidence-based practice, to reduce interference from symptoms of mental illness. It would also cover instruction to family or other supports, crisis prevention and amelioration, treatment planning under a licensed supervisor, and consultation with other providers.
- PSR: interventions that compensate for or eliminate co-occurring functional deficits and promote independent living in a natural community environment. Activities would include symptom management, independent living skills, social skills, interpersonal relationship skills, and community integration.
For both services, the slides say "QMHS+3 could bill either," with the service chosen by the content of the intervention. A qualified mental health specialist (QMHS) would remain limited to PSR. The threshold "would be raised to 200 units each," in light of removing CPST. For a side-by-side of the two services, see TBS vs PSR in Ohio.
Why ODM says the rules need to change
ODM gave three reasons. First, it needed to refine service definitions, taxonomy, and requirements after launching Next Generation Managed Care, OhioRISE, and Mobile Response and Stabilization Services (MRSS). Second, the slides say the Community Behavioral Health rules "ended up too broad, making them vulnerable to being used for profit rather than quality care." Third, unclear rule language confuses members, providers, managed care entities (MCEs), and state agencies.
The stated objective is to revise the rules to reflect clinical need and "support providers who are making an earnest attempt to render services appropriately." ODM paired the rule work with enhanced utilization management (UM).
Current rules vs the July 2026 proposal
| Topic | Current (as of September 2026) | ODM proposal, July 16, 2026 |
|---|---|---|
| CPST (H0036) | Covered under OAC 5160-27-02; defined in OAC 5122-29-17 | Eliminated from rule |
| TBS (H2019) | Goal-directed supports and solution-focused interventions (5160-27-08) | Psychoeducation, evidence-informed supportive interventions, crisis prevention, treatment planning, consultation |
| PSR (H2017) | Individual only, not group (5160-27-08) | Restore and support functioning and skills in the community |
| UM thresholds | CPST 200 units; TBS and PSR 200 units combined, per calendar year | TBS 200 units and PSR 200 units, each |
| Who can bill TBS | Relevant bachelor's or master's degree, or high school diploma plus three years of experience | QMHS+3 may bill TBS or PSR by intervention content |
| Who can bill PSR | Unlicensed practitioner, 18 or older, high school diploma, mental health training | QMHS remains limited to PSR |
| 90-minute reduction | 50 percent rate after 90 minutes same day for CPST, and for TBS and PSR in an office setting (5160-27-03(C)) | Removed for TBS and PSR |
| TBS Day Treatment | Governed by OAC 5160-27-06 | Structure more like IOP and PHP; possible rename to "MH Day Tx"; staff ratios and telehealth expectations |
| ACT (5160-27-04) | Current ACT rule | Ensure integrity without a prescribed fidelity requirement; look beyond the per diem rate |
IOP is an intensive outpatient program and PHP is a partial hospitalization program. ACT is assertive community treatment.
The slides also propose more detail on exclusions, stronger links to the assessment and treatment plan, no overlap with nursing facility per diem services, "co-occurring capable" language, and a definition of group services that separates them from TBS Day Treatment. For 5160-27-03, ODM proposes more detail on selecting the place of service code.
What is final today and what is only proposed
What is final: the UM requirements ODM announced in a May 12, 2026 bulletin, effective July 1, 2026. CPST individual (H0036) has 200 units (50 hours) per calendar year and CPST group (H0036 HQ) has 120 units. TBS individual (H2019) and PSR (H2017) share 200 units combined. TBS group (H2019 HQ) has 120 units.
These are pass-through thresholds. No authorization is needed to start a service, but one is needed to continue once a client reaches the limit. Plans must authorize these rehabilitation services for at least 90 days. The full code list is in our guide to Ohio Medicaid behavioral health prior authorization thresholds.
What is proposed: everything in the July 16 slides. The slides do not give an effective date. They also do not say whether the "200 units each" figure would appear in rule text, in UM guidance, or both, and they do not separately address CPST group (H0036 HQ).
Compliance note: keep billing CPST, TBS, and PSR under the current rules and thresholds until a revised rule is filed and takes effect. A slide deck presented for feedback does not change coverage, and a claim is judged against the rule in force on the date of service.
What removing CPST would mean for CPST-heavy agencies
Many agencies built their community programs around CPST. If the proposal is adopted, three areas change.
Staff roles. CPST work would have to fit TBS or PSR. Under the slides, staff at the QMHS+3 level could bill either service, while QMHS staff could bill only PSR. Staff who deliver CPST psychoeducation today but hold only QMHS status could lose that work.
Treatment plans. ODM wants TBS and PSR "informed by assessment and treatment plan." Goals written broadly for CPST may not support a choice between TBS and PSR. Each objective should point clearly to one function: symptom-focused psychoeducation (TBS) or functional skill restoration (PSR).
Documentation of intervention content. Since the intervention decides the code, the progress note has to show it. A note that says "met with client in community" will not show whether the work was TBS or PSR.
Audit tip: ODM asked what decides whether a provider bills CPST or TBS. Have a written answer for your agency now. If you cannot explain the difference in one sentence, your notes likely cannot either.
Agencies in Minnesota face a similar shift. See the ARMHS changes for 2027 and what ARMHS is. Note that H2017 means ARMHS in Minnesota and PSR in Ohio.
How Ohio agencies can prepare now
Inventory CPST volume by staff credential
Pull 12 months of H0036 and H0036 HQ claims. Group units by rendering staff and credential level. This shows how much CPST work could move to TBS, how much only to PSR, and which staff could not bill either under the slides.
Map interventions to the TBS and PSR definitions
Sample CPST notes and sort each intervention into the proposed TBS or PSR purpose. Mark anything that fits neither. That list is your agency's real answer to ODM's question about service delivery impact.
Tighten treatment plan linkage
At each plan review, write objectives that name the function (symptom reduction or skill restoration) and the intervention type. Then every note can cite the objective it serves.
Keep records organized
The rule package may change what auditors look for. Keep role-based access and audit logs in order, as covered in our HIPAA compliance guide. Most of that guide applies to Ohio agencies too.
Where to watch for the filed rule
As of September 2026, no filed version of the 5160-27 rule package could be confirmed. Check three places:
- ODM's rules page and provider bulletins. ODM posts draft rules for public comment through its rules page and email notices.
- The Register of Ohio. Filed rules and their rule summaries appear here.
- The Joint Committee on Agency Rule Review (JCARR). Filed rules go through JCARR review before they take effect.
When a filed version appears, compare it line by line with the July slides. A filed rule can differ from the first proposal.
How Trustora helps
Trustora runs an Ohio Behavioral Health program on its configurable program runtime, alongside its Minnesota programs. Services, codes, forms, and rules are defined as configuration, so the program definition can be updated when ODM's final rules change which services exist. Client records carry the Ohio Medicaid ID, and claims carry NPI and taxonomy.
Staff record individual and group services, assessments, treatment plans, and progress notes. A readiness check runs before a service record becomes a claim, and claims are built from signed service records as 837P, with 277CA acknowledgments and ERA posting. Contact Trustora to walk through your CPST, TBS, and PSR mix.