The supervision requirements are contradictory to the new changes from the Board of Counseling (BOC). The CPST regulations for an LMHP only to be able to provide supervision not only contradict the recent BOC regulations, but it also impedes on learning and growth opportunities for LMHP-Es. Additionally, the staffing shortages of licensed individuals will make it increasingly difficult for providers to meet the 1:9 supervision ratio requirements and provide appropriate level of care. LMHP-Es should be permitted to do all the work of an LMHP as they are under strict guidance already while enrolled in supervision and obtaining hours towards licensure. Additionally, new regulations also permit QMHPs with the appropriate trainings and experience to provide clinical supervisions under the BOC which has not been included in the CPST regulations.

In addition to the LMHP requirements for supervision, the weekly supervision requirement for QMHPs also contradicts the BOC regulations. QMHPs have underwent appropriate supervision and hours of direct service in order to be licensed as a QMHP and should be permitted to obtain monthly supervision rather than weekly. Increasing the supervision burden for a professional level of support is counterintuitive.