The draft does not provide solutions to Virginia’s ongoing workforce shortage and, in some ways, makes it worse.

• Requiring a senior-level LMHP to be available 24/7 is not feasible for most agencies.
  
  

• Increasing LMHP components within CPST is unrealistic given the current supply. Most LMHPs are unwilling or unable to take on extensive home visits given existing caseload demands.

• Team-based approaches are promising but impractical in rural areas where clients may live an hour away from the office, requiring multiple staff to travel long distances. This further strains staffing capacity and budgets.

• Limiting the ability to do 1 hour of services at an office- what happens if they are suggested for group psychotherapy (can only 1 hour occur only?), what if individual psychotherapy occurs as well as group, how will that be able to be billed.  It is difficult enough to find LMHP's let alone have them drive an 15-60 minutes to see a client, access to using the office setting may eliminate some of that challenge on staffing.  
• The amount of tasks that an LMHP supervisor will have to do is unrealistic and none of that is billable so the budget will take a huge hit.  How will companies be able to stay open with the staffing plans and limited caseload hours?  This needs to be clarified as it doesn't work out numbers wise.

The current proposal will really hurt agencies especially in rural areas.  The limited hours billed don't even allow for full-time employment if I'm understanding the units to 15 minutes, but perhaps I'm misreading- not very clear regardless.  More things for LMHPs to do, less hours for QMHPs is going to strain an already unstable workforce.  Wasn't this suppose to help that issue.  I feel we will lose a lot of providers to these strong and increased rigid regulations.