1. Training Requirements Remain Unfunded and Unphased
While training expectations are clearer in the updated draft, they remain extensive and unfunded. There is still no guidance regarding cost coverage, time requirements, or phased implementation. For rural CSBs facing workforce shortages, mandatory training during regular work hours will directly reduce service capacity unless offset by funding or rate adjustments.

2. School Coordination Expectations Remain Undefined
The draft continues to reference alignment between CPST services and school-based plans but does not clarify expectations for coordination with schools, participation in IEP meetings, or management of confidentiality conflicts between FERPA and HIPAA. No model MOUs, templates, or implementation guidance have been provided, leaving CSBs to independently navigate complex interagency requirements.

3. Caseload and Supervision Requirements Are Overly Complex for School Settings
The caseload formulas and supervision tracking requirements remain highly complex and were expanded in the updated draft. These requirements do not account for school calendars, closures, or fluctuating enrollment and will be difficult to operationalize without standardized DMAS tools or simplified limits.

4. Accreditation Timeline Remains Unrealistic
The draft does not address concerns regarding the feasibility of achieving accreditation within 18 months. Many accrediting bodies require longer timelines, and school-based CPST models may not align neatly with existing accreditation standards. No flexibility or technical assistance language has been added.

5. Financial Viability Concerns Were Not Addressed
Reimbursement rates remain unchanged despite increased non-billable expectations for supervision, coordination, documentation, and school collaboration. The draft does not allow billing for indirect services such as coordination with educators or IEP teams, nor does it offer start-up or capacity-building support.

6. Administrative Burden Has Increased
Weekly team meetings, expanded supervision requirements, and detailed documentation expectations remain in place. Flexibility for virtual supervision or reduced meeting frequency was not incorporated. These requirements will reduce direct service time in already resource-limited school environments.

7. Implementation Timeline Remains Aggressive
The updated draft does not include a pilot phase or delayed rollout. Introducing multiple new requirements simultaneously places a significant strain on schools and CSBs and increases the risk of inconsistent implementation and compliance findings.

We support the intent of expanding access to trauma-informed behavioral health services in schools. However, without clearer guidance, funding support, simplified compliance structures, and realistic timelines, the CPST–School Setting model will be difficult to implement sustainably in rural communities. We strongly encourage DMAS to engage in further stakeholder collaboration and consider phased implementation, funding adjustments, and operational flexibility prior to finalizing the regulations.