After reviewing the draft provider manual for CPST services, I have grave concerns:

• CPST presents significant financial and operational challenges for mental health agencies including not being cost effective, posing threats to both revenue stability and workforce stability.
• Reimbursement rates do not align with actual costs such as salaries, training, travel, and supervision making sustainability unrealistic.
• CPST is billed by time units; when clients cancel, reschedule, or no-show staff costs remain the same.
• There is already a severe shortage of providers in the mental health field and the requirements for CPST will only make that worse.
• Those of us living in rural areas have even more challenges.
• TDT can provide up to 25 hours of support each week and CPST is capped at 28 hours per month. This will increase the risk of academic failure, suspensions, or being placed in restrictive settings.
• CPST requires 8 hours of parent/family engagement per month. Unfortunately, the majority of children needing services do not have that kind of support which will end up preventing many children from getting the crucial support they need.

As someone who works for a community service board; I feel as though moving forward would be devasting, leaving adults and children without critical supports and put providers out of business. Please reconsider!