As a TDT Supervisor, I am very concerned regarding how the model that is being presented will be a replacement for TDT. The levels that are presented are very vague and confusing. What will the criteria be for school based interventions (i.e. replacement for TDT).  Due to increased behavioral needs at all ages and the increased intensity of the behaviors within the school setting TDT type services are showing an increase in need. Data shows that if the service is able to be implemented earlier that the service can be effective. The current criteria does not always allow for the service to be implemented in a proactive approach versus reactive.  Furthermore, the current inconsistencies with approvals by MCO's is making this service harder to get for students who are in desperate need of the service. With the new model implementation at this stage, the levels and criteria being presented is very confusing and it seems that the program may be harder to access which is not beneficial for our students and families, nor being proactive. 

The presented idea of using the modalities that are typically implemented by masters level staff are now going to be asked to be used by bachelors level staff is very concerning due to lack of education, experience, and training. Masters level staff typically gain experience and training through internships with such models where the utilization of bachelors level staff will not have that experience. 

There is information regarding restricted caseloads. If this level model is going to be implemented there should be consideration to caseload sizes based upon the level that each individual is on. A level one client would not require as much attention as a level 6 client.