I am going to list several concerns or questions below around the CPST School regulations.

Can we please have a definition for Clinical Director.  In a CSB setting the Clinical Director can manage multiple programs so the regulation of only being over 9 staff pretty much knocks a CSB out of the possibility of providing this service.  If we look at this as what at our CSB is the Assist Director of school based services and her staff is just the people that report directly to her then that would be acceptable.  In our catchment area we serve over 30 schools and would love to offer this service to the students but because of our size we would not be able to provide the service.  

The regulations state that we should collaborate with the IEP team.  Has this been discussed with Department of Education because at some schools, providers are not invited to the IEP meeting in general.

Why is the DLA-20 not an acceptable assessment tool when the adult version is for adult CPST?

This redesign was supposed to be budget neutral but you have created a service that requires staff to be on call 24/7 to their clients.  That is not budget neutral.  It is not reasonable to expect that from staff without additional compensation.  We also have spent the last couple of years building a crisis continuum.  Why would we not utilize those services for these individuals.  This is provider choice.

We also spend an enormous amount of time training crisis staff to appropriate handle crisis situations.  It would be a better service for trained crisis staff to provide crisis services.

The supervision requirements are also excessive.  Appropriate clinical supervision is important and you have to balance the needs of the staff along with the needs of the students and the needs of the school.  

The CANS assessment has not been released.  8 months is not an appropriate length of time to get all of this set and everyone appropriately trained.  We are going to have many individuals that are going to lose very important services IIH, TDT and MHSB and we need to be ready as a CSB to take care of those individuals.

Thank you for your time to read this.