As with regulation for adult CPST services there continues to be a conflict between the requirements to provide 24/7 crisis supports for individuals receiving CPST and Appendix G services that are often accessed through 988 Contact Centers.  A requirement for CPST providers to limit access to the Statewide Crisis Service continuum may violate the rights of citizens enrolled in these services and place undue pressure in diverting individuals from essential care during the time of a crisis.  There is no mechanism to determine if a caller to 988 has access to a CPST provider and verification of the same could prove costly for services that are designed to meet critical safety needs. 

Additionally, proposed rates and service limits do not support the required availability and capacity to respond in a timely fashion to such crises.