Section: 4.2 Agency Oversight

Supervision feedback (general)

• Describes supervision as more experienced staff supervising less experienced, but structures supervision based on education/licensed status not actual experience.
• QMHP are eligible to supervise based on board of counseling/DHP guidelines.  CPST has no structure to support QMHP supervising QMHP-T and BHT.  Instead, suggests that QMHP are paraprofessionals and require weekly supervision. 
• CPST guidelines refer to QMHP (bachelor level) staff as paraprofessionals with BHT (associates degree).  De-incentivizes use of QMHP staff.
• LMHP-eligible staff are receiving clinical supervision that requires 1 hour of supervision for every 40 hours of direct support per licensing requirements.  Do they need to also have 1 hour of weekly supervision by site supervisor who may or may not be approved to provide clinical supervision?
• Use of BHT in higher acuity tier but not in lower tier does not seem to make clinical sense.
• With only LMHP able to provide supervision, workforce will be greatly impacted, especially in fields where the legacy services relied heavily on QMHP staff, many with years of experience.
• Structure of the program staffing does not adequately cover the need to provide 24-hour care/response. 
• Who will provide the Adult Mental Health Rehabilitative Supports and Services training?  Will it cost money and be available on demand?
• Will staff have to create a report on caseload sizes, tiers, and time spent providing care?
• More administrative/documentation burden could be allocated to QMHP staff but assigned to LMHP staff including quarterlies and team meetings.
• With a team of 9 staff that are licensed eligible, QMHP, or BHT, a supervisor would spend 9 hours a week in supervision or 36 hours a month- nearly 25% of work week in just 1:1.  With weekly team meeting, supervisor will only be available 30 hours a week for service delivery and administrative tasks.

Section: 4.3 LMHP Oversight

• Clarification of the word “direct” is needed.  Does this mean within the same agency? On-site? Certain level of hours of supervision?
• 24-hour coverage by a licensed-type provider is a significant increase in cost to provide services.  Further, there is a significant workforce shortage for Licensed providers.
• The requirement for the licensed provider to provide in-person services every 90 days further increases the cost to provide services which is exacerbated by workforce shortage.  Management of providing this level of direct service as well as the required hours of supervision based on the provider type of staff decrease the feasibility of managing the multiple, increased requirements.

Section: 4.4 Collaborative Behavioral Health Services/Supervision of team members

• Minimum face to face team meeting weekly

Section: 4.5 Supervision of Individual Staff

• 9 staff max per LMHP
• Weekly supervision for all non-licensed staff
• Supervision documentation maintained in employee records

Section: 4.5.1 Supervision of LMHPs

• All licensed are required to receive one-hour a month of supervision from Clinical Director.  What happens if more than 9 LMHPs are employed and there is the 1:9 supervision caseload max for the Clinical Director?

Section: 4.5.2 Supervision of LMHP-R, LMHP-RP or LMHP-S

• Matrix-based caseload as outlined is over-complicated and restrictive to a point to be a barrier to ability to provide this service.

Section: 4.5.3 Supervision of QMHPs, QMHP-Ts, BHTs

• The number of supervision hours is excessive, particularly for the QMHPs
• Matrix-based caseload as outlined is over-complicated and restrictive to a point of creating a barrier to the ability to provide this service.

Section: 4.5 Staff Caseloads

• The staff caseload maximums are not fiscally feasible based on the rates presented for the services.  The weights by caseload paired with the matrix methods described create a overly-complicated, fiscally expensive requirements which are a barrier to the ability to provide this service. 
• The requirement for “formal log of caseload” every six months as the compliance requirement increases administrative burden and is operationally difficult based on the fluid nature of staff caseloads.
• Billable units limit further restricts the provision of service and the flexibility to maintain successful program model.