As a seasoned Children's Services Act Coordinator, I have many concerns regarding replacing TDT and IIH with CPST. Recently, our locality has seen a sizeable increase in children with mental health issues. Moving forward with this change in services would be devastating for many reasons. CPST does not even come close to comparing to TDT or IIH in regard to level of support offered. CPST provides for a dramatic decrease to the number of hours available per week and a lack of summer programming. This is simply not acceptable. Expecting these children to go three months without services is asinine. The lack of structure and support that summertime brings often escalates behaviors. It is imperative that these children are provided with the services that they deserve regardless of whether school is in session. Furthermore, CPST requires 8 hours of parent/family engagement per month. While I feel that family involvement is of the utmost importance, the children typically accessing these services do not have that luxury. Lack of family engagement will end up preventing many children from getting the help that they so desperately need. Lastly, this proposal will be financially devastating for service providers and localities. Our local CSB has estimated that providing CPST under the proposed guidelines would result in an annual deficit of several hundred thousand dollars. How could this possibly be sustainable? Due to the reasons mentioned above, localities will likely see an increase in referrals to access Children's Services Act funding to fill in the gap created by CPST. Many localities are going to be unable to shoulder this increased financial burden. I implore you to reconsider these unnecessary and unviable changes.