This service is not designed or regulated as a crisis service and while 24/7 emergency supports can be provided, this service type and individuals providing services within do not follow MCR regs or training requirements. Specifically: section 5.3 bullets #2, 5, and 7 are concerning. No one providing CPST will be required to be trained at the level a mobile crisis response team is trained and therefore this service should not immediately limit access to that. 988 is a valuable resource and individuals should be encouraged to utilize this resource when in crisis. For a service that is time-limited as CPST is currently outlined, stating that a crisis mitigation plan may NOT include use of or referral to a Crisis service is setting up clients to lack appropriate insight into their available resources upon discharge. Additionally, #7 is a very risky requirement for providers in rural areas or serving large geographies. On-call support via phone or Telehealth is fine, but requiring in-person response for someone serving a 45-60 min radius and now allowing them to be referred to 988 is ultimately negligent.

Additionally under section 8, bullet 2.b.i, it should be noted that MCR response is geographically dispatched. Does this mean if the closes MCR team should decline a dispatch opportunity in the event they are already enrolled in CPST? Often MCR teams will not know if CPST is already being provided by the agency.