As currently written, the draft CPST guidelines for in-home and community settings risk reducing access, worsening workforce shortages, and overburdening providers with administrative and clinical requirements that are not feasible in practice. Adjustments are needed to: build flexibility for rural service delivery, expand telehealth options, clarify caregiver expectations, reduce administrative burdens, andProvide realistic workforce and supervision supports Ensure training is accessible and will not put providers out of business.  There are a lot of challenges within this proposal.  In addition, perhaps there can be some examples of what the services could look like, as the tier 1 and tier 2 activities are very confusing and does not give a good picture of daily practicality.  Also clarifying is Outpatient Therapy a stand-alone service for these youth receiving services- meaning when this transitions over and the individuals that are receiving outpatient therapy, will they have to switch providers to one that can fit into the CPST?  Many of the clients are being seen in agency but some outside of the agency, individual choice.  How will that work?  There needs to be some more clarity.  Team approaches are also a wonderful support- how do you determine who bills if there are members collaborating together, both in a treatment meeting, both requiring to be in the same place? This plan provides lots of restrictions without much practical application.  Do the math and look at the numbers more closely- would you be able to pay even your most basic bills with the amount of hours you can bill?  How will employers keep staff, it's already hard enough now with all the unpaid drive time and administrative tasks but now this plan puts more burden- more clients means more drive time, less hours, less pay, etc.