While supporting the use of EBPs, we are concerned that the proposed referral requirements may unintentionally delay treatment and reduce person-centered decision making.

Questions include:

• Whether sufficient providers exist statewide for Assertive Community Treatment, Coordinated Specialty Care, Functional Family Therapy, and Multisystemic Therapy.
• Whether Community Services Boards will be expected to accept out-of-catchment referrals.
• Whether referral requirements may delay initiation of needed services.
• How individual preferences and informed choice will be incorporated into referral decisions.

The manual also appears to require referral when individuals demonstrate limited progress after 18 months, regardless of their preferences. Clarification is needed regarding whether individuals may decline referrals and continue receiving medically necessary CPST services.