This draft risks creating an even deeper access gap for children and adolescents. CPST is not a service most providers are offering right now, and the proposed requirements make it almost impossible for many agencies—especially smaller or rural ones—to even get started. By layering on strict accreditation, extensive paperwork, and multiple service mandates, the draft ensures that only a handful of agencies will be able to provide CPST. That means families already struggling to access care will face even longer waits or no services at all.

The impact will fall hardest on the children who need help the most: youth from low-income and working-class families, children of color, and families already involved in multiple systems. These are the young people most likely to be shut out by administrative delays, endless authorizations, and complicated eligibility standards. Requiring families in crisis to navigate more red tape is not trauma-informed care—it is policy that exacerbates inequities.

At the same time, the draft destabilizes services that are already crucial to the system. TDT, outpatient therapy, and other community supports are not optional—they are essential. Undermining these services in favor of a narrowly defined model means children lose the lifelines that currently keep them connected to school, family, and their communities.

Meanwhile, the workforce is being pigeonholed into a model that is not financially sustainable and already struggles to retain staff. Behavioral health is not a high-paying profession—it relies on dedicated providers who stay despite low wages. Burdening them with high caseloads, unrealistic supervision demands, and endless paperwork will accelerate turnover and make it harder for new clinicians to enter the field. That is a recipe for collapse in a profession that is already critically understaffed.

In the end, these rules send a clear message: that the state is willing to sacrifice both families and providers. But when kids end up in foster care, juvenile justice, or psychiatric hospitals, the state will pay far more—in human costs and in dollars. So why choose a path that hurts children, families, and the state’s wallet all at once?