QMHP-Ts should be permitted to provide Tier 1 support. If Tier 1 is considered a lower level of need as established via their CANs Lifetime score, then a lesser credentialed staff member should be qualified to provide support to these individuals. QMHP-Ts are significantly easier to staff and should be treated as QMHPs, not BHTs.

Additionally, Section 7.1.4.b - the outpatient counseling criteria is very counterproductive to the level of service being provided. Tier 1 was outlined as a lower level maintenance support, and outpatient counseling attempts should be considered as many individuals with SMI, talk therapy is not a clinically appropriate service.