Thank you for allowing me to comment on the proposed revision on the Behavioral Health Redesign.  Though the new proposal is linguistically rich in verbiage and may sound good on paper, I challenge the practicality of it.  For anyone who works in public schools, it is apparent that practical solutions are needed.  The public schools need 'boots on the ground' to make a real difference.  

     Therefore, let me address some of the challenges with the current proposal.  The CPST design will reduce the number of support hours for our students in schools by 72%.  This is a drastic difference, and one that will be felt by our school systems.  Providing direct service on the front end will prevent the need for proposed services retroactively.  Our children need direct services, not the indirect services that are being proposed.

     Eliminating summer programming for students will be a big mistake!  Summer programming provides the consistency our kids need to sustain and maintain their social and emotional growth.  This has been evidenced with academics on many occasions and is no different in regard for social-emotional health and learning.  Our children and their families are excited and look forward to the summer programs each year.  For children who often do not experience extracurricular activities and community events, this piece is crucial and has a large impact in many different capacities.  It assists in teaching social skills and emotional-behavioral skills and allows children to interact with their peers in a different environment.  It also serves as a respite for families and children can take those skills back to share with their families.

    Furthermore, if you have worked in a public school system, you will realize that parent involvement isn't always optimal, as much as we would LIKE it to be.  Requiring greater parent involvement may affect an agency's ability to deliver services.  Again, we need more direct services, not indirect.

     Lastly, increasing administrative requirements often places additional burdens on staff and directly impacts the time and resources available to give back to students and families in a practical manner.  While some administrative tasks are necessary, increasing those requirements only takes away from the population you are there to serve - the students.  We need direct services and practical solutions, like TDT.   I will say again, we need 'boots on the ground' to face the challenges that students and families are facing now.