Section: 2.1 CPST Teams:

• Team definitions represent an extensive increase in reliance on Licensed staff.  This will greatly increase the cost to provide the service as well as impact the ability of agencies to be able to offer this service due to the severe workforce shortage already evident for licensed-type providers. The proposed updated draft is still heavily reliant on L-Type staff.  Further, the Tier/Level Team composition remains overly complicated increasing operational burden.