I am concerned about the replacement of TDT with CPST. While CPST seems to have potential value as an individualized, community-based service, it is not an equal substitute for TDT. Removing TDT from the continuum of care would create significant service gaps for youth with the highest needs.

1. TDT provides 2-7+ hours of structured, therapeutic programming each day, often year-round. CPST, by contrast, is limited to 3-28 hours per month. The intensity of TDT is simply unmatched by CPST, leaving youth who require consistent daily therapeutic engagement without sufficient support.

2. TDT incorporates group-based treatment in a structured environment where youth practice skills with peers, build social competence, and benefit from therapeutic peer modeling. CPST, while permitting some group time, is primarily individualized and lacks the intensity of this essential group component, making it inadequate for youth who need greater amounts of supported peer interaction to develop social and behavioral skills.

3. TDT is delivered primarily in schools, bridging academic and mental health needs. This integration allows youth with severe behavioral or emotional challenges to remain in educational settings. CPST, while allowing some support in the school, is not school-based, and therefore cannot provide the same level of school support and classroom stabilization that TDT offers.

4. CPST requires active caregiver participation and availability for crisis consultation. While family engagement is critical, not all guardians have the capacity to meet these requirements due to work obligations, other caregiving responsibilities, or their own personal mental health/medical/etc barriers.TDT, by contrast, ensures children receive therapeutic services during the school day regardless of caregiver availability while still requiring involvement and communication with families regularly.

5. TDT serves youth with needs often identified as too severe for traditional school or outpatient settings—those at risk of hospitalization, removal from home, at risk of homebound placement, and demonstrating behaviors that lead to harm to themselves and/or others. CPST is designed for moderate to high needs in the home/community. These are distinct populations, and replacing TDT with CPST risks leaving the most vulnerable youth without appropriate care.

CPST is an important addition to the behavioral health continuum, but it does not replicate the scope, structure, or intensity of TDT. Eliminating TDT in favor of CPST will leave critical service gaps for youth requiring daily school-integrated therapeutic support.