The level of care model, in theory, would provide various levels of services for clients to access. Ideally, this should make access to services more accessible and help to be more proactive versus reactive; however, this structure appears to make services less accessible and more reactive. Services included in the most intensive levels such as FFT, MST, and HFW are all services that should be able to be accessed at a lower level, not simply waiting until the house is completely on fire with no way to recover. These services are not intended to be implemented at the lowest level, but over time they should decrease to lower levels as progress is made. This structure shown appears problematic when considering the fluid nature of such programs. Another concern with the presented levels is that services that follow evidenced based models that should be in place for specific timeframes may be presented with issues by categorizing them into certain levels. HFW for example is a 12–18-month service, but by this presentation, can only be accessed in level 5 or 6 when in reality it should be accessible in all levels as it moves through the model.

This then brings into question about the nature of implementation for providers. Currently there are separate services, but this new model shows that it will be one service with varying levels. Are providers going to be credentialed in all levels of care for CPST or only credentialed in certain ones? How are services going to move between levels? More consideration needs to be given to these areas. As a provider of services as well as a FAPT member, I am concerned with completely overhauling the current system versus addressing the areas within each program that need changes to be made. FAPT also approves many of these services if Medicaid is not accessible for a family, so it is important that there are clear standards for the services as it appears that it is not being replaced, but completely changing all of the requirements.