Overall

1. The service as defined will be very difficult to sustain financially.  The model relies heavily on licensed mental health professionals, already in short supply, and limits the number of hours that can be billed, regardless of need.
2. The service definition prohibits organizations providing CPST from referring individuals to crisis services run by the same organization.  This practice would prevent a resident who needs crisis services from using those crisis services developed by their locality and might result in long waits for CSU or CRC availability outside their locality. It makes it impossible for a CSB to deliver CPST services.
3. The evidence base supporting CPST relates to the evidence supporting Managing and Adapting Practice (MAP), a requirement for those delivering CPST services to children and adolescents. MAP is only one component of CPST.  
4. CPST does not address supports to individuals with ID/DD, other than those with autism.   

Sections

Section 2

1. The teams and tier matrix is complicated and documenting movement from one tier to another is excessively burdensome.
2. There is no definition for "younger children".

Section 3

1. In the list of assessments, it is not clear what "recommended" and "strongly encouraged" mean.  
2. It is not clear if the referral to Applied Behavior Analysis (ABA) when a primary diagnosis of autism is present is a requirement prior to receiving CPST, although the language within the draft is "shall." If so, it is not family or patient-centered as not all people with autism benefit from ABA.  Other services included in the list do not reflect family choice or issues of system capacity.  What if there is no provider in the area or there are lengthy waitlists?
3. There is no definition of "transition age youth." The training requirement is confusing.

Section 4

1. The caseload and supervision matrices are overly complicated.  The number of supervision hours is difficult to implement and sustain, particularly for QMHPs.
2. Caseload maximums are not fiscally sustainable.

Section 5

1. What does "CPST provider" mean in Section 5.3.5? Does it mean the agency providing CPST or does it mean the individual's actual assigned provider? 
2. Were the activities listed in the Care Coordination section included in the original rate study?
3. The requirements, proposed rate structure, and service limitations will prevent CPST providers from delivering the required level of crisis care. It is not fiscally sustainable.

Section 9

1. The prohibition of an agency delivering CPST to provide any of the crisis services in Appendix G prevents a CSB from providing CPST.
2. Does the requirement limiting covered services in a provider's DBHDS licensed office location include licensed group homes?