As a licensed MH provider and employee of a Virginia CSB for the last 10+ years, I do not support the current CPST draft nor the additional redesign components as proposed in the July update. 

CPST shows promise as an additional service, not as a replacement for other vital services. The current draft model demonstrates need for significant review and revision, with areas of concern clearly identified by previous comments. However, the general premise of the service provides an opportunity to meet the needs of individuals who may not qualify for the current services available or who may require an additional layer of support- CPST can fill these gaps. 

The current administrative burden and MCO inconsistencies have had a direct negative impact on the ability of agencies to sustain and fund the identified legacy services. This draft clearly documents increases in administrative requirements and MCO barriers, at the cost of actual abilities to provide appropriate amounts and levels of service- what is the trade off? Where is the positive impact? It is not with the clients, families, schools, communities, employees, or agencies- so who really benefits from this? 

This CPST draft and current redesign plan lack practicality and show the disconnect the individuals involved in its creation have with the current reality of working in the mental health field at any level. 

Come and spend a day with a staff providing therapeutic day treatment, skill-building, psychosocial rehabilitation, and intensive in-home. One day in each service- then consider if this plan is truly an appropriate replacement. 

If the current redesign plan and draft model moves forward "as-is", my current position will be directly impacted. I cannot and will not expect myself, my staff, and my coworkers to meet these asinine requirements- especially at the costs for the client, community, and agency (which have all been thoroughly explained in previous comments). If the plan and draft continue to move forward and IF my employer implements these changes, I will be forced to leave my position. I refuse to explain to a client, family, or community member that the service and level of support that is needed is no longer available and that there is no comparable replacement.