The draft excludes CPST if an individual qualifies for EBPs such as MST, FFT, ACT, or CSC. This creates multiple problems:

• Gaps in service will occur if EBPs are not available locally or have long waitlists (common in rural areas).

• Agencies that do not provide EBPs may struggle to identify eligibility or locate providers, creating an unfunded administrative burden on LMHPs.
  
  

• Being able to plan and staff for cases will be nearly impossible if many cases are also meeting requirements for some of these very limited EBPs.  
• In addition the EBPs do not provide support in the schools.
• Will the school based hours and community/home based hours be shared or are they looked at separately - if they are shared, these kids are not going to get the support they will need, impossible
• The team meetings- will all members be able to bill for time reviewing the ISP if they are present or will just one provider, even though it states that team members should be there- this should be clearer 

This restriction prevents providers from planning caseloads effectively and may limit the ability to serve families who could benefit from CPST alongside—or blended with—other community-based services.