Section: 2.1 CPST Teams:

• The Tier/Level Team Matrix system is overly complicated and will lead to increased operational burden that will impact ability to provide care with no obvious increase in benefit to the individual served.
• Team definitions represent an extensive increase in reliance on Licensed staff.  This will greatly increase the cost to provide the service as well as impact the ability of agencies to be able to offer this service due to the severe workforce shortage already evident for licensed-type providers.

Section: 2.2 Service Goals for Adults:

• The requirement and wording that CPST is not intended to be an indefinite, ongoing services demonstrates a lack of understanding of the populations served.  Many individuals served experience persistent, serious mental illness which impacts them across the lifespan.  The inability to access these lower acuity, lower cost supports will result in an increased reliance for more intensive, expensive levels of care such has state and private hospitalization or justice-system related costs.

Section: 2.3 Service Goals for Children:

• Please provide more specificity on how the term “younger children” is defined.
• Will the requirement that “the majority of services must be delivered with a caregiver or legally authorized representative participating with the youth as the services are delivered” be applicable to services delivered within the school setting?