Proposed Regulations continue to be unclear it regards to what actual service implementation will look like.

The requirement for 24/7 in-person crisis support by CPST team is likely to impact service delivery overall.  You can't expect a provider to be responding to crisis all hours of the day and night and continue to provide scheduled care to other recipients of the service. Why the limitation on utilizing Comprehensive Crisis and Transition Services? These providers literally specialize in crisis support. If a continuum of care already exists - use it. Additionally, the reimbursement rate for these services is not adequate for the expectation of the CPST providers. 

The Team/Tier structure provided is confusing. Does each agency decide what team/tier they offer? 

The availability of MAP training is completely insufficient this close to implementation. 

When will the CANS Lifetime be available? 

Will the requirement of caregiver participation be waived for an adolescent seeking services on their own? What clarity can be provided on "the caregiver must commit to participating in 30 min of SPST covered services components a week"?

What clarity can be given on "active participation by school team in treatment planning and implementation"?