The following summarizes feedback regarding the "Exclusions and Service Limitations" section received from our members since the draft policy was released:

Exclusion and Service Eligibility Concerns

• Concurrent service restrictions (e.g., MST, FFT, ACT, CSC, crisis) could leave youth without necessary support, particularly those with developmental disabilities but no co-occurring mental illness.
• Affiliate service bans discourage collaboration and integrated care models, undermining continuity across programs.
• The exclusion rules appear to apply outside school settings, which could mean students receiving school-based CPST are barred from other community services (e.g., IOP or ABA), an unintended and restrictive outcome.
• Sections C and D of the exclusions are internally inconsistent and confusing; the intent and boundaries are unclear.
• Section I (24/7 availability) seems contradictory; requiring around-the-clock access sounds like a crisis service even though crisis services are excluded.

Documentation and Reimbursement

• The volume of required documentation and measurement tools creates significant non-billable workload; providers question why this time isn’t reimbursable.

Seasonal and Setting Limitations

• Section G (summer services) lacks clarity: if school is not in session, it’s unclear what types of services can continue and how coverage should be structured.
• Excluding summer camp or school-break programs eliminates important continuity for youth who rely on consistent behavioral supports.

Systemic and Practical Impacts

• Restrictions on concurrent services and classroom-based programming represent a regression from past models (e.g., TDT, IIH) that allowed more flexible, integrated support in schools.
• The overall structure risks reducing access to services, discouraging collaboration, and fragmenting care for students with complex needs.